REACH: About the Naming and the Identification of Substances

Under the REACH Regulation, companies have the responsibility for the safe use of their substances along the entire supply chain. Companies, their manufacturing processes, products and customers are highly individual and differ from each other considerably. Consequently, there is no generally applicable solution for all situations. Moreover, Guidance documents and helpdesks cannot give exhaustive answers to all questions – even less so as their answers are never legally binding25; they only provide support in the practical implementation or interpretation of the REACH Regulation. Proposals for solutions to many questions and problems, which arise in practical implementation, as well as relevant methods will be developed only over the next few years. Companies can assume their responsibility under REACH in a useful way only if they are free to benefit from the flexibility given by the REACH Regulation. For this reason, Guidance documents and other implementation aids (e.g. national helpdesks or associations) should not limit this flexibility; they should focus on hands-on information and methods for REACH implementation in operational practice.