REACH “Distributors”

Requirements for Interflon sales organisations

According to REACH (art. 3.12), Interflon sales organisations are “distributors”. A distributor is any natural or legal person, including retailers, with a seat in the Community, who stores and trades in products that are manufactured by “producers” or “formulators” such as Interflon BV.

A distributor’s main duty is to issue information about the goods the distributor distributes and use of the goods, both "downstream" (e.g. from supplier to customer), and "upstream" (from customer to supplier). This information relates to the properties of the substances, the risks involved in their use, corresponding relevant exposure scenarios and recommended control measures. This includes, for example, Interflon B.V. providing its customers with material safety data sheets. The distributor plays a central role in the information flow within the supply chain. This role is, in fact, comparable to the role that the distributor had before REACH.
In addition, the distributor is a downstream user in terms of taking applicable risk-reducing measures regarding transport, storage etc., as well as the issuing of relevant information to its staff.

REACH stipulates that Interflon “Distributors” are required:

• To pass all information about chemical substances (exposure scenarios, risk control measures, new information about dangerous substances, MSDS etc) to its customers. These documents will to this end be published on this website. Users that so desire can receive e-mails in the future keeping them abreast of the most important as well as recent changes.
• To collect information about the use of a substance or preparation and pass this to Interflon BV ("Formulator") in order to enable identified use.
• For those methods of use about which information was obtained, distributors will have to supply the producer with exposure scenarios and other relevant information regarding safe use of a chemical substance, so this information can be included in the Material Safety Data Sheet (MSDS).
• To pass new information about a product to Interflon BV.
• Provide the customer with any information about the possible presence of regulated or worrisome substances
• In case of identified use of a substance, to pass information that might lead to the adjustment of risk control measures in a MSDS to Interflon BV.
• To store all data regarding a substance or preparation for no less than ten years and to make this available to the authorities on request.

For the Interflon sales organisations, the REACH ordinances generate a system of registration requirements that applies to all Interflon products that they sell. They would prefer to comply as flexibly and as efficiently as possible with the new requirements of information exchange with users. Interflon distributors will therefore collect all the information provided about what its customers (“downstream users”) do with the substances they sell. This information will be carefully documented and communicated to its supplier Interflon (“formulator”).

Safe use by “internal staff”

REACH determines that Interflon sales organisations are also “downstream users”. Information about the safe use of the substances will therefore be shared with people who (may) handle these substances in demonstrations, use and transport. The staff in question consists primarily of technical advisors, lubrication consultants and logistical staff.

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