ECHA has completed phase 3 of their enforcement initiative. Exporters – heads up!
Major recommendations:
• The high non-compliance rate for only representatives’ needs to be addressed by the industries and industry stakeholders concerned. Only representatives have the highest non-compliance rate, which is twice the average rate for non-compliant companies. Only representatives are often non-compliant not only due to missing registrations, but also due to the breach of Article 8 of REACH regarding the duties of only representatives.
• The high non-compliance rate for importers needs to be addressed by the industries and industry stakeholders concerned. Importers have a non-compliance rate at least twice that of manufacturers. Importers are often not aware and not familiar with their registration obligations under the REACH regulation.
• The high non-compliance rate for actors which are not related to the chemical industry and chemical distribution sectors needs to be addressed by the industries and industry stakeholders concerned. These actors have a non-compliance rate twice that of the chemical industry and distribution sectors. These actors are often not aware and not familiar with their registration obligations under the REACH regulation.
Full report here