Shell supports the underlying goals of REACH, which include placing greater responsibility on industry to manage the risks that chemicals may pose to health and the environment. This is consistent with the Shell commitment to promote the responsible production, use and handling of the products made.
During the first two registration deadlines (1st December 2010 and 1st June 2013, respectively) Shell legal entities registered more than 600 petroleum and petrochemical substances. Shell is now preparing to meet the 1st June 2018 deadline. Shell will continue to collaborate with customers on the products Shell sells and with suppliers to gather all of the required information products and their downstream uses.
Shell registrations (or pre-registrations) do not cover the manufacture of these products outside the European Union and the importation of these products into the European Union by non-Shell companies.
In case you are sourcing Shell products from non-EU Shell manufacturing sites and want to import those into the European Union, or if you are located outside of the EU and are sourcing Shell products from EU manufacturing sites and export them back to the EU (so called re-import), different measures need to be taken to obtain REACH coverage:
- In case you are an EU importer and source Shell products from Shell manufacturing sites outside the EU, you should ensure that your import is covered through a (pre-) registration conducted by an appointed Only Representative (OR) - according to REACH Article 8 - of the Shell manufacturing/formulating entities outside the EU. REACH does not make a distinction between direct and indirect imports into the EU. However, handling direct and indirect imports require different provisions.
- If you are located outside of the EU and are sourcing Shell products from Shell EU manufacturing sites and export them back to the EU (so-called re-import), different measures need to be taken to obtain REACH coverage through existing Shell (pre-) registrations.
Re-import can be covered if the re-imported substance has been registered by the Shell EU Legal Entity already and if it
- remains the same, i.e. same chemical identity or becomes a constituent monomer of an exempt polymer
- is not mixed with identical substances sourced from other supply chains.
In case a re-imported substance cannot be covered by a Shell registration, the EU importer needs to have its own (pre-) registration if the re-imported volume is >1 t/a.
Alternatively, the non-EU exporter (provided that he’s a manufacturer or formulator) can appoint an Only Representative to cover the EU importer through the OR’s (pre-) registration.
For further advice, please approach your usual business contact.
Along with the implementation of REACH, all Safety Data Sheets provide information on the safe use of chemicals and the respective risk management measures. An interactive guide introduces the key features of REACH compliant Safety Data Sheets.