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.
For every product Shell Legal Entities in the European Economic Area (EEA) sell a REACH registration is in place. Shell will continue to collaborate with customers to ensure ongoing compliance for the products Shell sells and with suppliers to gather all of the required information products and their downstream uses.
Shell registrations do not cover the manufacture of these products outside the EEA and the importation of these products into the EEA by non-Shell companies.
In case you are sourcing Shell products from non-EEA Shell manufacturing sites and want to import those into the EEA, or if you are located outside of the EEA and are sourcing Shell products from EEA manufacturing sites and export them back into the EEA (so called re-import), different measures need to be taken to obtain REACH coverage:
- In case you are an EEA importer and source Shell products from Shell manufacturing sites outside the EEA, you should ensure that your import is covered through a registration conducted by an appointed Only Representative (OR) - according to REACH Article 8 - of the Shell manufacturing/formulating entities outside the EEA. REACH does not make a distinction between direct and indirect imports into the EEA. However, handling direct and indirect imports require different provisions.
- If you are located outside of the EEA and are sourcing Shell products from Shell EEA manufacturing sites and export them back to the EEA (so-called re-import), different measures need to be taken to obtain REACH coverage through existing Shell registrations.
Re-import can be covered if the re-imported substance has been registered by the Shell EEA Legal Entity already and if the substance
- 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 EEA importer needs to have its own registration if the re-imported volume is >1 t/a.
Alternatively, the non-EEA exporter (provided that he’s a manufacturer or formulator) can appoint an Only Representative to cover the EU importer through the OR’s 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.