Legal Aspects

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threshold for import of a substance which falls under the REACH regulation

What is the threshold for import of a substance which falls under the REACH regulation? The threshold for import of…

What is the threshold for import of a substance which falls under the REACH regulation?

The threshold for import of a substance which falls under the REACH regulation is 1 tonne. Please follow this link for Details

https://echa.europa.eu/support/registration/your-registration-obligations/do-i-reach-the-one-tonne-a-year-threshold

REACH Restriction - legal text.

Link to the REACH Restriction - Legal Text: The REACH restriction text can be found here: https://eur-lex.europa.eu/eli/reg/2020/1149/oj    

Link to the REACH Restriction - Legal Text:

The REACH restriction text can be found here: https://eur-lex.europa.eu/eli/reg/2020/1149/oj

 

 

Would our supplier have to train us in the competent and safe handling of packed material containing Diisocyanates

Would our supplier have to train us in the competent and safe handling of packed material containing Diisocyanates. Your supplier…

Would our supplier have to train us in the competent and safe handling of packed material containing Diisocyanates.

Your supplier is not obliged to train you, this is the responsibility of the employer.

Does the supplier need a confirmation from his customer

Does the supplier need a confirmation from his customer (recipient of the diisocyanate-containing product)? No, the supplier must ensure that…

Does the supplier need a confirmation from his customer (recipient of the diisocyanate-containing product)?

No, the supplier must ensure that the professional or industrial customer is provided with information about the training requirements and the supplier must put the following statement on the packaging: "As from 24 August 2023 adequate training is required before industrial or professional use.” A confirmation from the customer is not required.

Customer, who falls into different section of isocyanat applications?

If there is a customer, who falls into different section of isocyanat applications, does he need different training courses or…

If there is a customer, who falls into different section of isocyanat applications, does he need different training courses or can he or she combine it into only one training course (cross-over)?

In the very rare cases these employees would need to undergo different training courses.

Do we as downstream user apply as own initiative for the training, or will our suppliers approach us?

Do we as downstream user apply as own initiative for the training, or will our suppliers approach us? It is…

Do we as downstream user apply as own initiative for the training, or will our suppliers approach us?

It is the obligation of the employer (in this case the customer) that his employees are being trained.

If the customer has more than one supplier, which supplier is the responsible?

If the customer has more than one supplier, which supplier is the responsible? It is the obligation of the employer…

If the customer has more than one supplier, which supplier is the responsible?

It is the obligation of the employer (in this case the customer) that his employees are being trained.

How about the users with exposure outside EU?

How about the users with exposure outside EU? The REACH legislation is an EU law. It is not applicable outside…

How about the users with exposure outside EU?

The REACH legislation is an EU law. It is not applicable outside the EU.

Legal situation EU Countries

What is the legal situation on every European country on the diisocyanates restriction. Are they publishing any legal text about REACH…

What is the legal situation on every European country on the diisocyanates restriction. Are they publishing any legal text about REACH Trainings in other European countries?

It will depend on each EU member state if they want to adopt their national legislation regarding OSH. Best to contact your ministry for labor, where normally those topics are being handled.

Article 6

The training shall comply with the provisions set by the Member State in which the industrial or professional user(s) operate.

Member States may implement or continue to apply their own national requirements for the use of the substance(s) or mixture(s), as long as the minimum requirements set out in paragraphs 4 and 5 are met.

Do we as a distributor have to inform our clients about trainings?

Do we as a distributor have to inform our clients?

The legal text defines that information on how to get access to the course should be communicated throughout the supply chain and  it’s the responsibility of the operators placing the substances and mixtures on the market to ensure that training courses are available to the recipients of such substances or mixtures.

It is the obligation of the employer (in this case the customer) that their employees are being trained.

No questions yet.

Do we need to train our sales, administrative and warehouse?

Do we need to train our sales, administrative and warehouse staff although we do not re-pack/ re-fill such products?
We simply store them for distribution at times.

We recommend that your warehouse staff is being trained, even if you do not unpack or pack, but there might be emergencies.

No questions yet.