CONTRACT & TOLL MANUFACTURING
The reverse also applies for EU companies and UK REACH .
UK-based contract manufacturers can submit Downstream User Import Notifications ( DUINs ) to the Health & Safety Executive ( HSE ) for those EU REACH-registered substances for which it was a downstream user in the two years prior to 1 January 2021 . They should have also grandfathered any existing EU REACH registrations they held into UK REACH . As preregistration does not exist in UK REACH , UK contract manufacturers may find substances and products they are looking to import need to be registered under UK REACH .
Managing supply chain issues
Many contract manufacturing customers will have their own formulation that they want creating which may come with an approved list of suppliers . If that lists includes EU rather than UK suppliers , this can have repercussions , particularly with regard to REACH regulations again . EU suppliers may be unwilling to trade with UK companies , possibly in a bid to avoid the additional paperwork of trading outside the EU .
Having an approved supplier list also provides a more limited pool of suppliers to turn to . UK-based suppliers are likely to have a higher price , whereas new EU suppliers may need to be set up as a new supplier or may have more stringent processes to adhere to .
Unforeseen contract manufacturing costs can also appear in the form of force majeure being declared by suppliers , which can drive up costs and disrupt the supply chain . Airedale Group mitigates these issues by ensuring we have multiple suppliers in place , although this can also come at a cost if there is an industry shortage driving up prices or if we have to use a distributor or other third party .
Despite the many regulatory challenges of offering a contract manufacturing service , it can be a profitable and rewarding process which encourages innovation in blended solutions , boosts your NPD credentials and plays a part in bringing original and advanced products to market . ●
J j
Daniel Marr
COMMERCIAL DIRECTOR
AIREDALE GROUP daniel . marr @ airedale-group . com www . airedale-group . com
JAN / FEB 2024 SPECCHEMONLINE . COM
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