Compliance in the supply chain
A unique compliance solution for complex multi-stage supply chains under REACH, Turkey REACH (KKDIK) and UK REACH
According to the European REACH regulation and its counterparts KKDIK in Turkey and UK REACH in Great Britain, importers are subject to the obligation to register all imported chemical substances, unless substances are exempted from this obligation.
To enable importers to be exempted from these registration obligations, the respective regulations provide that non-domestic manufacturers and formulators can appoint a so-called Only Representative (OR), who registers the respective substances on behalf of the manufacturer/formulator and thus makes the respective importers so-called Downstream Users (DU). For this purpose, the OR must keep records of the respective importers as well as their annual imported substance quantities, which leads to problems in complex multi-stage non-domestic supply chains, since indirect customers, suppliers and compositions of formulations are not known in many cases. Compliance with the OR’s record keeping obligation would therefore only be possible by disclosing Confidential Business Information (CBI) in the supply chains, which may even be contrary to competition law rules if the OR is a related legal entity of the manufacturer/formulator.
Therefore, in these cases, neither the manufacturers/formulators (represented by the OR) nor the importers can fulfill their obligations without disclosing such CBI and also risking loss of business.
To address this problem, we have developed a web-based solution – the Chemservice OR-Trustee.
The web-based Chemservice OR-Trustee system replaces the previous REACH-Code-Model system, which was developed back in 2008 as a unique solution for REACH and has since been used by leading companies in the chemical industry worldwide, including their downstream supply chains with several hundreds of participants. In addition to REACH, the new system is now also available for Turkey REACH (KKDIK) and UK REACH.
For Turkey, the system is already in use and can be accessed at tr.or-trustee.com. Further information on the system as well as a user manual can be found on this website.
The systems for the EU and UK will be released for use shortly.
The benefits of the Chemservice OR-Trustee system
- The system is a self-service portal, eliminating unnecessary waiting time by filling out Word forms, email communications, etc.
- Information on the exact composition of raw materials is stored exclusively in a separate offline system to which only the respective Only Representatives have access.
- Only information that is already known is exchanged between suppliers and customers.
- The certification process follows the supply chains step by step, from manufacturers/formulators to importers, automatically checking all data entered for plausibility and thus reducing unnecessary errors.
- The trustee system controls the covered product quantities along the supply chain to prevent inadmissible use.
- The Only Representatives of the manufacturers/formulators remain responsible for the accuracy of the information that is submitted and certified by the system.
- All confirmations are valid immediately without having to wait for feedback from importers about their imported substance quantities first.
- The OR-Trustee system allows to provide compliance information to authorities in a simple, quick and safe manner.
- No need for individual contracts between downstream users and Chemservice.