Information in the supply chain

Rules pertaining to information in the supply chain are a part of REACH that is of great practical relevance. Among the requirements is that suppliers of a substance or a mixture in many cases must provide the recipient with a so-called safety data sheet. This is the case, inter alia, where the substance meets the criteria for classification as hazardous or if it is a PBT or vPvB substance.

The safety data sheet, which is to be compiled in accordance with Annex II, shall contain, inter alia, hazards identification, information on handling and storage, toxicological and ecological information, disposal considerations, and regulatory information.

Any actor in the supply chain who is required to prepare a chemical safety report must place the relevant exposure scenarios in an annex to the safety data sheet. The safety data sheet shall be provided free of charge no later than the date on which [1]

the substance or mixture is first supplied. However, the sheet need not be supplied where hazardous substances or mixtures offered or sold to the general public are provided with sufficient information to enable users to take the necessary measures as regards the protection of human health, safety, and the environment, unless requested by a downstream user or distributor.22

In cases when a safety data sheet is not required, the supplier must provide the recipient with information on whether the substance is subject to authorisation and details of any authorisation granted or denied in this supply chain, details of any restrictions imposed under REACH, and any other available and relevant information about the substance that is necessary to enable appropriate risk management measures to be identified and applied. (Arts 31 and 32.)

There is also a general obligation incumbent on each actor in the supply chain to communicate information to the next actor or distributor up that chain. The obligation to communicate covers new information on hazardous properties, regardless of the uses concerned, and any other information that might call into question the appropriateness of the risk management measures identified in a safety data sheet supplied to that actor. Distributors must pass on such information to the next actor or distributor up the supply chain. In this way the information should also reach the manufacturers and importers who have the primary responsibility to assess the risks of their substances and communicate appropriate safety and management measures.

Every downstream user shall identify, apply, and, where suitable, recommend, appropriate measures to adequately control risks identified in the safety data sheet(s) supplied to her, in her own chemical safety assessment, or in any information on risk management measures supplied to her in accordance with the rules on communicating information down the supply chain for substances for which a safety data sheet is not required. (Art 37.)

  • [1] An ‘exposure scenario’ is the set of conditions, including operational conditions and risk management measures, that describe how the substance is manufactured or used during its life-cycle andhow the manufacturer or importer controls, or recommends downstream users to control, exposures ofhumans and the environment (Art 3).
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