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Tasks of intermediate producers

If your buyer produces from your chemical substance another chemical substance, then you have a good chance for the cheaper intermediate registration. According to REACH the intermediate does not need to remain within the premises in all cases, it is quite possible that your end product is an intermediate according to REACH.
The intermediate registration is significantly cheaper than a normal chemical substance registration.

It may be important to discuss whether it is possible to treat the substances as transported isolated intermediates.

During a transported isolated intemediate registration the manufacturer or importer confirms that he is manufacturing and/or using the substance under strictly controlled conditions and he confirms himself or states that he has received confirmation from the users that the substance is used under strictly controlled conditions.

Registering both as intermediate and normal substance only makes sense, if registering as intermediate reduces the quantity of all the substances to be registered in a way that they fall in a lower registration limit-category. Registering as intermediate only can be significantly cheaper both from the point of view of the registration fee and the amounts payable to the lead registrant.

REACH instructions provide a very precise definition for strictly controlled conditions.


Would you like to know what kind of strictly controlled conditions you must establish in your own and your suppliers’ factories?


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You may feel that these 6 tips are a drop in the ocean. This is not everything in which I can help you.




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