REACH OUT – Import af artikler

Summary

A preliminary study has been conducted regarding an analysis of the roles of the Danish trade sector in relation to REACH.

Twelve out of 350 invited Danish trade companies accepted to participate in the project activities, regarding a questionnaire based interview and a follow up seminar on REACH roles and needs for support. One of the primary reasons for the low participation is companies low awareness of REACH in combination with a belief that the companies are outside the new regulation.

A questionnaire and a supportive paper on the likely roles of trade companies was submitted to the participants. The materials were simplified as far as possible to ease the applicability of the materials for non-chemists. In spite of this effort the Worthing was a great barrier for the ability of the companies to fill-in the questionnaire.

Most of the companies are not familiar with existing chemicals regulation as they have had no other obligations than to pass information from suppliers to their customers of safety data sheets. Suppliers normally take care of registering the chemical products in the Danish Product Register and the needed classification and labelling work. In general therefore, the trade companies have no knowledge of the terminology of chemicals and are therefore limited in their possibilities to actual identify a “chemical” among the many goods they deal with.

The limited knowledge of both terminology and legislation is a major hindrance of the companies motivation to start preparing for REACH and – if motivated – a hindrance for achieving an overview of their chemicals assortment as a basic activity for prioritization of potential proactive measures.

Trade companies often purchase chemicals in volumes above 1 tonnes per year and trade the chemicals to many customers in often very small volumes. Normally the supplier provide the chemicals in volumes ready for handling over to the customers. In few instances the trading company is repacking the purchased chemicals. In general the companies have no overview on hand of the countries from where they purchase the goods.  The present (limited) analysis support earlier findings, that there are a significant purchase from countries outside EU.

The dialog in the product chain is in general good, although there are trade companies which does not disclose the name of the supplier to customers as well as customers which do no wish to inform the trade company of the uses.

Most trading companies offer their customers extensive services regarding the choice of goods for specific uses. The participating companies are in general  in favour of extending the service activities to also covering relevant REACH issues, provided sufficient knowledge and tools are available.

It is recommended that information materials are elaborated, targeted the various sectors in the trade area, which make use of the ordinary technical language applied in the sector; that the companies are offered education which include on-the-job training; that the sector is stimulated to offer REACH service to their customers;  that operational chemical management systems are offered to the trade sector and finally, that especially the SME trade companies are offered an affordable REACH consultancy at least for a transition period.

 



Version 1.0 Juni 2008, © Miljøstyrelsen.