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Compliance in Complex Supply Chains: A Unique Solution for Multi-Stage Supply Chains Under REACH, Turkey-REACH (KKDIK), UK REACH and Korean REACH (K-REACH)

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Dieter Drohmann, Thomas Schaefer, Christopher Cohrs


According to the European REACH regulation and its counterparts KKDIK in Turkey, UK REACH in Great Britain and K-REACH in Korea, importers are subject to the obligation to register all imported chemical substances, unless substances are exempted from this obligation. To enable importers to be exempted from these registration obligations, the respective regulations provide that non-domestic manufacturers and formulators can appoint a so-called Only Representative (OR), who registers the respective substances on behalf of the manufacturer/formulator and thus makes the respective importers so-called Downstream Users (DU). For this purpose, the OR must keep records of the respective importers as well as their annual imported substance quantities, which leads to problems in complex and multi-stage non-domestic supply chains, since indirect customers and suppliers as well as compositions of formulations are not known in many cases. Compliance with the OR's record keeping obligation would therefore only be possible by disclosing Confidential Business Information (CBI) in the supply chains, which may even be contrary to competition law rules if the OR is a related legal entity of the manufacturer/formulator. Therefore, in these cases, neither the manufacturers/formulators (represented by ORs) nor the importers can fulfil their obligations without disclosing such CBI and also risking loss of business. In the following article, a solution to this problem is presented using the example of EU REACH, which is also used in Turkey and Great Britain and works very well there. In Korea, the system is used in a slightly modified form.

Dr Dieter Drohmann, CEO Chemservice Group, Email: d.drohmann@chemservice-group.com; Thomas Schaefer, Director Data & System Services, Chemservice S.A., Email: t.schaefer@chemservice-group.com; Christopher Cohrs, Team Leader Supply Chain Compliance, Chemservice S.A., Email: c.cohrs@chemservice-group.com.

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