Does a supplier outside the EU always make me an importer under REACH?
Products purchased outside the EU are not necessarily seen as imported
products. The following example describes a situation wherin a product is
purchased outside the EU, but not considered imported as meant under REACH.
Company A purchases a product from DSM Composite Resins AG, which is situated
in Schaffhausen, Switzerland, i.e. outside the EU. The products are
manufactured by subsidiaries of the AG in several European countries and are
delivered directly from those EU sites to company A in the EU. Company A is
invoiced by the AG. As the manufacturing sites in the EU are the manufacturers
or importers of substances contained in those products, those sites will be
pre-registering any relevant substances contained in those products. As we
interpret the REACH regulation, company A should not be regarded as an
importer of such products since they are of EU origin and remain physically in
the EU.
