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What should you do?
REACH impacts the whole lubricants supply chain. Whether you are a manufacturer, importer or downstream user, make sure you know your responsibilities to ensure continuity of supply.
Everyone in the lubricants supply chain has a role to play in the implementation of REACH. Each party needs to be aware of their respective obligations and be prepared to communicate information on product usage and safe handling procedures, up and down the supply chain.
As a customer, it is important to ensure your supplier within the European Union (EU) registers all substances in a product for the ways in which you use it. In support of this, be prepared to provide information to your supplier about how you use the product. You should pay particular attention to the potential for human and environmental exposure.
Make sure you review the safety handling procedures proposed by your supplier and inform the supplier if these procedures do not cover your use of the product. If your supplier is outside the EU, you may have obligations as an importer.
In order to evaluate how much support we can give to you if you are importing Shell lubricants into Europe – please contact your usual Shell representative for further information or visit our contact us page.
As an importer of a product into the EU, you may have registration obligations. Make sure you contact your supplier to determine whether you should (pre-) register, or whether your supplier has appointed an Only Representative who will register the imported substance instead of you.
In the latter case you become a Downstream User, with the obligations as set out for customers in the preceding section.
As a supplier, you are required to understand how your product is handled throughout the supply chain. This information, in particular the potential for human and environmental exposure, will be required in your substance registration or that of the original EU manufacturer or importer.