Letter to the editor

摘要

Dear Peter We have read the two articles covering the REACH Regulation in the July 2008 issue with great interest. In FETSA we are closely tracking the issue and we regularly receive various questions from members and other trade and industry associations. Of special interest for those who operate within a worldwide scope (and who isn't nowadays) is of course the one concerning the identity of the Registrant of one or more substances if the pertaining product arrives from outside the European Economic Area (EEA = EU+EFTA). The producer for certain is not established in the Community and the identity of the 'importer' may be unclear. Unfortunately, REACH has in no way a connection with the Inco terms of the International Chamber of Commerce, which are made specifically for identifying the various responsibilities often with regard to insurance and fiscal matters, of the actors along the supply chain. If REACH had been tuned to this self-regulatory and long-standing system, the question of the identity of the Registrant for substances thus imported from outside the EEA would in all likelihood be much more obvious to answer.