SUPPLY CHAIN MANAGEMENT
Figure 4 - Flow chart of the Trustee system
This is done for all product supplies that contain material from a non-EU manufacturer and which are intended to be imported , in whole or in part , into the EU . Using a database , the trustee tracks , among other things , all the information on suppliers , customers and importers , as well as the relevant product information and quantities , and ultimately issues import certificates ( Figure 3 ) to EU importers regarding the covered imported products and quantities . This ensures that all parties involved can continue their business without having to exchange CBI with each other and enables all stakeholders to fulfil their REACH obligations . Figure 4 shows a schematic diagram of the process . The benefits of the Trustee system are as follows :
• It is a self-service portal , eliminating unnecessary waiting time filling out Word forms , e-mail communications , etc
• Information on the exact composition of raw materials is stored exclusively in a separate offline system to which only the respective ORs have access
• Only information that is already known is exchanged between suppliers and customers . The trustee uses the data exclusively in communication with the enforcement authorities ; it is not passed on to participants in the supply chain
• The certification process follows the supply chains step by step , from manufacturers or formulators to importers , automatically checking all data entered for plausibility and thus preventing unnecessary errors
• The system controls the covered product quantities along the supply chain to prevent inadmissible use
• The ORs of the manufacturers and formulators remain responsible for the accuracy of the information that is submitted and certified by the system
• All confirmations are valid immediately , without having to wait for feedback from importers about their imported substance quantities first
• The system makes it possible to provide compliance information to authorities in a simple , quick and safe manner
• There is no need for individual contracts between DSUs and Chemservice
Conclusion
The OR-Trustee system is a simple procedure to ensure REACH compliance along the product flows and avoid double registrations , saving resources and costs . The overall control of the coverage confirmations ( e . g . verification of covered product quantities , validity of certificates , etc .) is performed centrally and databasedriven , thus preventing accidental or even deliberate manipulations . The system is applicable even in the case of re-imported substances , where it is relevant that no more material is re-imported into the EU than was previously exported from the EU . Combinations of the different scenarios and multiple supply chains are also easy to implement . The administrative efforts and costs are very low for all parties involved . Due to the great demand to cover indirect imports , especially in complex multi-stage supply chains with imports to the UK or Turkey and in the course of the registration obligations of chemicals in the respective countries , the system has also been introduced in these regions . In South Korea , a slightly modified model was implemented due to legal requirements . The system has been facilitated because the respective REACHlike chemical control legislations established the institution of the OR . Without the OR function , indirect imports could not be adequately reflected . Finally , it should be noted that this system will be made available to all ORs in the EU , UK and Turkey so that supply chains can be fully mapped and traced with a unified database-driven system . •
* - Also contributing to this article was Dr Dieter Drohmann
J j
Christopher Cohrs
TEAM LEADER SUPPLY CHAIN COMPLIANCE
CHEMSERVICE SA c . cohrs @ chemservice-group . com www . chemservice-group . com
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