Many companies still miss their registration duties


The third REACH-EN-FORCE project by ECHA's Enforcement Forum shows that 13 % of inspected companies have missed some of their REACH registration duties. Only representatives and importers are more at risk of non-compliance than manufacturers of substances.

Helsinki, 10 December 2015 – Within the REACH-EN-FORCE-3 project, enforcement authorities in 28 countries inspected 1 169 companies and 5 746 substances in 2013-2014.

In total, 13 % of companies did not fulfil some of their registration obligations. In most of these cases, the non-compliant companies failed with registration duties related to one or two substances from their portfolio. However, 2 % of companies had not registered any substances at all.

The project was coordinated by ECHA's Enforcement Forum and implemented in close cooperation with national customs authorities. The aim was to investigate the registration obligations of manufacturers, importers and only representatives.

Only representatives, who register substances on behalf of importing downstream users, are more likely to be in breach of their REACH-related obligations than other registrants. A dedicated investigation of supply chains involving more than one Member State was carried out by inspecting 104 only representatives. A third of them (32 %) did not comply with their specific only representative information duties as described by Article 8 of REACH.

The flow of information in the supply chain between only representatives and importing downstream users was also poor. It was often difficult to establish the structure of the supply chain as the respective importers could not specify the correct only representative and the only representatives did not keep reliable records of represented importers.

"The high non-compliance rate for only representatives and importers needs to be addressed by these types of companies and their stakeholder organisations," says ECHA's Executive Director Geert Dancet. "I also strongly advise third country exporting companies to keep their only representatives informed annually of the exported volumes to all their importers in the EU/EEA so that registration obligations are correctly identified."

The project has proven that REACH enforcement authorities in the 28 participating countries have established effective cooperation with customs. This cooperation allowed enforcement authorities to make use of data from individual customs declarations in their routine inspections of REACH duties. Enforcement authorities and customs were encouraged to continue this type of cooperation in the future.


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