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REACH Update: November 2007
Posted: November 7, 2007
page 3 of 4
• Producers of cosmetics and personal care products located in the EU are usually downstream users and have no obligations to register ingredients under REACH
• Producers of cosmetics and personal care products located outside the EU have no obligations to register
• It is the importer of the products into the EU who has to register the individual ingredients when present in quantities of 1 ton or more per year, and when not yet registered by an upstream manufacturer
• The noncommunity manufacturer can nominate an “only” representative to fulfill all obligations of an importer under REACH
• In case of the nomination of an “only” representative, the importer is considered a downstream user
Further Useful Information: The European Chemicals Agency (ECHA) offers a Web site with several helpful tools for everyone affected by REACH. Since June, various REACH Guidance Documents have been published.
Competent Authorities (CA) and Help Desks: Each EU member state has to appoint a competent authority or competent authorities with responsibly for performing the tasks under REACH in cooperation with the European Commission and the ECHA. Also, member dtates have to establish national help desks to provide advice to manufacturers, importers, downstream users, etc: