FREQUENTLY ASKED QUESTIONS

The Automotive Industry Guidelines (AIG) on REACH contains a comprehensive list of Frequently Asked Questions.  Only questions that do not appear on the AIG are addressed in this FAQ.  You may download the Automotive Industry Guidelines here. (link to http://www.acea.be/index.php/news/category/reach/)

1.) The GMREACH.com website notes that “submitting your contact information to General Motors does not constitute fulfilment of your REACH obligations, including, but not limited to, pre-registration or registration.” How and where will suppliers pre-register or register?

Pre-registration and registration of substances and preparations will take place online through the European Chemical Agency’s website (http://echa.europa.eu/).  In order to benefit from extended deadlines for phase-in substances, potential registrants under REACH must pre-register their substances with ECHA between 1st June 2008 and 1st December 2008 (inclusive). 

The initial intent of General Motors’ REACH website (www.gmreach.com) is to discover which of its suppliers intend to pre-register and which do not, in order to ensure that all substances and preparations will be pre-registered by the appropriate dates. 

2.) We are a GM division that exports components to GM in Europe (Saab, Opel, etc.).  To manufacture that component, we receive parts from our suppliers.  What are our REACH obligations?

When you export an article to General Motors Europe (GME), the receiving GME legal entity is the importer under REACH and has to pre-register, if necessary.

As an exporter to the EU, you are obligated to deliver any relevant data to GME that are needed for GME to register or notify substances.

You must obtain this data from your upstream suppliers.  In case a non-GM supplier exports any substance or preparation into the EU, we strongly recommend that this company nominates an Only-Representative in the EU that will assume the role of importer.

3.) We recently received the REACH Awareness letter from General Motors.  However, we are currently not suppliers to GM or GME now, though we may be suppliers to GM or GME in the future.  Is it necessary for us to submit our contact information to General Motors?

We suggest that you submit your contact information to General Motors.  By completing the brief survey, your company can indicate that it currently does not supply substances, preparations or articles to General Motors, and as such, REACH is not applicable to your company.

In the future, new GM suppliers will indicate their compliance with REACH during the technical review process through GM Global Purchasing Supply Chain (GPSC).

4.) We recently received the REACH Awareness letter from General Motors.  However we only provide services to GM, not substances, preparations or articles.  Is it necessary for us to submit our contact information to General Motors?

We suggest that you submit your contact information to General Motors.  By completing the brief survey, your company can indicate that it currently does not supply substances, preparations or articles to General Motors, and as such, REACH is not applicable your company.

5.) My company is a supplier to General Motors, but not a supplier to General Motors Europe.  Do I need to pre-register or register?

It depends upon where your company is located.

If you are a supplier that is located within the EU and your company supplies a substance, preparation or article to GM outside the EU, you have REACH obligations.

If you are a supplier that is located ouside the EU and your company supplies a substance, preparation or article to GM outside the EU, you DO NOT have REACH obligations.

6.) Do solvents need to be pre-registered?

All substances that meet the tonnage criteria, including solvents, must be pre-registered.  

7.) Do all SVHCs need to be pre-registered or registered or should they be only authorized?

All SVHCs that meet the tonnage criteria must be pre-registered and registered.  If the SVHC is on the candidate list (to be published in 2009) and meets the tonnage criteria, it will also need to be authorized.

AdditionaIly, when an SVHC is present in an imported article in quantity above one ton per importer/producer per year and the SVHC is present in the article with a concentration of 0.1% w/w and if the importer/producer can not exclude exposure to humans or the environment during normal or reasonable foreseeable conditions of use including disposal, it must be notified.

8.) Wastes are exempted from registration. Do the substances recovered from waste need to be registered or not?

At the present time, it is not clear.  Please note that the criteria for defining when waste is no longer considered to be waste after recycling (so-called End of Waste criteria) are currently under development in relation to the ongoing revision of the Waste Framework Directive. Such a decision shall be taken within the legislative framework of the Waste Framework Directive. Only when a decision has been taken in accordance with the provisions of the Waste Framework Directive that waste meets the End of Waste criteria and consequently is no longer waste, does the recovered material fall under the provision of the REACH Regulation.

It is important to note that once waste is recovered and another substance, preparation or article is produced, the REACH rules will in principle apply again, as they would to any other substance, preparation or article manufactured, produced or imported in the EU. In specific cases, where a recovered substance is the same as a substance which has already been registered, an exemption from the registration obligation may apply. More guidance on recovery is available in section 1.6.4.5. of the Guidance on registration available on the ECHA website at: http://reach.jrc.it/docs/guidance_document/registration_en.htm

9.) Do additives to polymers need to be pre-registered?

YES. Any additives to polymers that meet the tonnage criteria must be pre-registered.

10.) I am a Downstream User and I do not want to Pre-register. I want the Manufacturer/Importer of the substance and / or preparation to pre-register.  Is it OK to check “Our company does not intend to pre-register”.

YES. You will receive an email at a later date, which will ask your company to confirm why you do not intend to pre-register.

11.) I have forgotten my user name and / or password. How do I retrieve it?

When you first submitted your contact information to gmreach.com, you received an email confirming that information.  You may also click on the Have you forgotten your user name or password? link located on the bottom of the Submit Contact Info or Edit My Information pages.

12.) My company doesn’t have a DUNS number. How do I get a DUNS number?  Is it expensive?

If your company does NOT currently have a DUNS number, you may obtain one, free of charge, by visiting the Dun and Bradstreet website: http://www.dnb.com/us/.  Select your region in the upper right hand corner to navigate to the geographic region you wish. 

13.) Our Global Ultimate DUNS Number is in the gmreach.com database, but not all legal entities affiliated with it are listed. How should we proceed?

Please send the Company Names and DUNS numbers of any legal entities affiliated with your Global Ultimate DUNS number that are not contained in the gmreach.com database to us by clicking here.  We will add them to the database and notify you so that you may edit your information accordingly.

14.) Our company has a Global Ultimate DUNS Number for each geographic region.  Should we register each region separately?

Yes.  Each Global Ultimate DUNS number must be separately registered.