Low volumes represent a big compliance challenge because many small to mid-sized businesses either ship chemicals in that range or use chemicals in that range in their products.
To find out exactly what substances you might be responsible for in your products, mixtures and articles, most companies are now using product ingredient tracking software. Tracking software culls a Bill of Materials and queries suppliers for substance-level data. Over time, the data is collected in an organized fashion in a rational database. This means reports can be run and meaningful information and compliance docs can be extracted easily and quickly from the data. Actio Corporation has put together a checklist for what to look for in REACH compliance software. Included is WEEE and RoHS regulations -- because the process for supplier data collection is similar can can be cross-purposed for all. Complimentary download, but you are asked to enter your name and email.
You likely have upcoming registration obligations under REACH if your business:
- Manufactures chemicals or imports them from outside the EU above one (1) tonne per year
- Manufactures or imports any product (mixture, article), as it may contain substances that need to be registered individually