Key Responsibilities for EU importers of Chemical Substances and mixtures under the REACH, CLP and Rotterdam Regulations

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The Irish Health and Safety Authority (HSA) has produced an information sheet which outlines the key responsibilities for EU importers of chemical substances and mixtures under the REACH, CLP and Rotterdam Regulations, for which the HSA is the relevant Competent Authority in Ireland.

  • Import means the physical introduction into the customs territory of the EU.
  • An importer, in accordance with the REACH and CLP Regulations, is defined as any natural or legal person established in the EU who is responsible for import.
  • Under REACH and CLP import is deemed to be placing on the market.
  • Companies who source their chemicals from within the EU are not importers and do not have any importer duties as they are considered to be downstream users.

Key responsibilities include:

  • Importers are responsible for submitting a REACH registration to the European Chemical Agency (ECHA) for each substance, whether on its own or in a mixture, or incorporated into an article with intended release, imported into the EU in quantities equal to or greater than 1 tonne per year.
  • Non-EU manufacturer(s) cannot register substances but they can appoint an Only Representative (OR) to represent them in the EU. The OR completes the registrations on behalf of the EU importer(s), thus removing that duty from the EU importer.
  • Importers must supply safety data sheets (SDSs), which should be prepared in accordance with the requirements of REACH Annex II, for all hazardous chemicals placed on the EU market.
  • Importers must contact and notify the Irish National Poison Centre regarding the use of their emergency number in Section 1.4 of the SDSs, where appropriate.
  • An importer cannot import a chemical substance that is listed in Annex XIV of REACH (past the sunset date) for a use or use it himself, unless the use has been granted an authorisation by the EU Commission.
  • An importer cannot import a chemical substance that is listed in Annex XVII of REACH, unless it is for a use that is permitted in accordance with specific conditions identified in Annex XVII.
  • Importers must classify, label and package all hazardous mixtures in accordance with the Dangerous Preparations Regulation until the 1st June 2015. However importers can opt to classify, label and package in accordance with the CLP Regulation (EC NO. 1272/2008) voluntarily ahead of that date, if they wish. From 1st June 2015, importers must classify, label and package hazardous mixtures in accordance with the CLP Regulation. However, if a mixture is already placed on the market on the 1st June 2015, it does not have to be relabelled or repackaged until 1st June 2017.

Further Information is available from
HSA Information Sheet
European Chemicals Agency website
HSA’s Chemicals Helpdesk; email or call 1890 289 389
HSA Safety Data Information Sheet 
Irish National Poison Centre