No clear ideas on how and if real enforcement will occur, but except for a
very few issues in REACH, response to obligations don't "port" across import
streams. That is to say, it doesn't matter what anyone else is doing for a
specific product, whether they be the OEM or a distributor, or a gray-market
re-seller, an EU importer is directly and totally responsible for the REACH
conformance of the products they import. An importer could have contractual
arrangements with their suppliers and push conformance obligations to the
supplier, but the importer is still on the hook.
One (external to the EU) can sell non-conforming products to unsuspecting
importers (in the EU) all day long without being in danger of REACH
violations. It might violate the fine print terms and conditions in the
contracts one has established with their in-EU clients.
A more detailed response depends on who is internal and external to the EU in
the supply chain you describe, and who is a client of who (whom?)
Regards,
Lauren Crane
Product Regulatory Analyst
Corporate Product EHS Lead
Applied Materials Inc.
Austin, TX 512 272-6540 [#922 26540]
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e-mail.
Christine Rodham <[email protected]>
Sent by: [email protected]
04/08/2009 02:01 PM
Please respond to
[email protected]
To
[email protected]
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Subject
Re: REACH Enforcement
List Members,
We have an OEM that has a product we want to sell in Europe that is not REACH
compliant. Since the OEM introduced the product into Europe via their reseller
are there any ramifications to us for selling this product without it being
compliant to the REACH Directive?
The product is a network Intrusion Protection /Monitoring Device which could
be used with a Server.
Any input on REACH enforcement in general is appreciated!
Thank you in advance!
Christine Rodham
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This message is from the IEEE Product Safety Engineering Society emc-pstc
discussion list. To post a message to the list, send your e-mail to
<[email protected]>
All emc-pstc postings are archived and searchable on the web at
http://www.ieeecommunities.org/emc-pstc
Graphics (in well-used formats), large files, etc. can be posted to that URL.
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Instructions: http://listserv.ieee.org/request/user-guide.html
List rules: http://www.ieee-pses.org/listrules.html
For help, send mail to the list administrators:
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Mike Cantwell <[email protected]>
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