Representing more than 3000 Non-EU suppliers including 70% of clients come from China, CIRS is one of the largest Only Representatives in the world. During past years, CIRS has dealt with great majority of inquiries from EU importers regarding EU REACH Supplier Regulatory compliance issues. Among these inquiries, questions concerning Documents/Certificates verification occupied 25% in total. For the purpose of better communication among Non-EU manufacturers, Only Representative and EU importers to fully comply with EU REACH Regulations, we composed this guide on how to work/cooperate together to achieve EU REACH compliance through supply chain.
How to do this?
There are three elements you need to consider when you import.
Step 1: Check out EU REACH compliance status of suppliers and tonnages coverage.
Firstly, you need to check whether the substance is pre-registered/registered; for this process, you need to request REACH documents from your supplier first when you are notified that the Only Representative had completed pre-registration/registration.
a) You need to require Power of Attorney which states that the Non-EU manufacturer had appointed the Only Representative to fulfill obligations under EU REACH; and,
b) You may need to require a confirmation letter together with submission report that confirms the Only Representative had completed pre-registration/full registration for relevant substances.
After you provide those three documents, the Only Representative will confirm with the Non-EU manufacturer whether you are their clients: If yes, the Only Representative will check the documents and revert to you whether the documents are genuine or not.
P.S. This step is quite important as we found many Non-EU manufacturer or exporter modified CIRS original document.
Step 2: Check out CLP notification and SDS/ESDS
Non-EU companies and REACH only representatives do not have direct obligations under CLP regulation. However, non-EU companies might be required to provide the latest Safety Data Sheet according to REACH & CLP or submit C&L notifications for each of its importers. The most urgent thing for EU importers/manufacturers of chemicals is to submit C&L notifications. Besides, SDS must be authorized according to EU CLP. Usually it starts with an inquiry concerning about whether the C&L notification was submitted or SDS was updated or whether an ESDS is available.
CIRS will check out the state and then reply to the EU importer. If the obligations were fulfilled, CIRS will provide required documents to importer; If not, CIRS will contact the Non-EU manufacturer and they may appoint us to fulfill those obligations. Otherwise CIRS will revert to the importer that the documents are not available and they shall fulfill those obligations themselves since the Non-EU manufacturers didn’t committed CIRS to do those for them.
Step 3: Check out the tonnage coverage certificate
With EU REACH tonnage coverage certificate (TCC)(Template), you can show the enforcement authorities of your states that your substances and volumes are covered by the (pre-) registrations of the Only Representative. You shall ask for this certificate every time before you import your products to the EU. When CIRS receive TCC request from you, CIRS will contact your supplier directly and asked whether they would like to cover your imported tonnages. If so and there is capability, CIRS will issue the certificate to you soon. Both you and your suppliers can request this certificate. You can fill in an application form and send it to email@example.com or simply send your supplier’s name, the substances you import and the volume of each substance to the above email. You can also ask your suppliers to provide this certificate along with their products. They can apply the certificate through CIRS RCUM System and CIRS will provide tonnage coverage certificate to them.
There are four types of documents that need to be verified: Power of Attorney, Confirmation Letter, Tonnage Coverage Certificate, OR certificate and registration Certificate.
Power of Attorney is a document that shows the Non-EU manufacturer has appointed the Only Representative and the Only Representative will fulfill REACH obligations instead.
The confirmation letter is a document that confirms CIRS is acting as Only Representative for Non-EU manufacturer and has completed pre-registration/registration for relevant substances.
OR certificate is similar to confirmation letter, but OR certificate is issued by OR to prove to EU importer that the OR has completed pre-registration for several substances for a certain company while CIRS confirmation letter is issued to Non-EU manufacturer.
The Tonnage Coverage Certificate (TCC) is a certificate that proves that the importer’s imported tonnages are covered by the registration OR made and the importer will be regarded as downstream user. They don’t need to undertake the imported tonnages themselves. The registration certificate is a certificate that proves the formal registration has completed and the registration number will be listed. Please be aware of the above documents and remember to send them to us for verification if there is necessary.
For general verification inquiry, please send request to Info@cirs-group.com