Compliance with EU REACH, KKDIK, UK REACH

EU REACH

For imported products, MCE is regarded as importer and either holder of importer registrations or covered by OR registrations and thereby considered downstream user. Therefore, our customers are downstream users with no registration obligations.

The substances contained in imported products either have been registered by their manufacturer via an Only Representative or via MCE as importer, are exempt from registration requirements or below the registration threshold.

Products manufactured in the EU mainly contain EU raw materials.

KKDIK (Turkish REACH)

Substances subject to registration can only be registered by manufacturers or Turkish importers. MCE will therefore only register substances in products manufactured in Europe.

For imported products it is the responsibility of MCI or the Turkish importer to ensure that the substances subject to registration are registered.

The registration deadline for substances in all tonnage bands is 31st December 2023.

UK REACH

Similar to KKDIK only manufacturers and UK importers face registration obligations under UK REACH. MCE will only take care of the registration of substances in products manufactured in Europe.

For imported products it is the responsibility of MCI or the UK importer to ensure that the substances subject to registration are registered.

The registration deadlines under UK REACH have been postponed as shown below:

Deadline (last date for dossier submission)TonnageHazardous property
27 October 20261000 tonnes or more per year
  • Carcinogenic, mutagenic or toxic for reproduction (CMRs) - 1 tonne or more per year
  • Very toxic to aquatic organisms (acute or chronic) - 100 tonnes or more per year
  • Candidate list substances (as at 31 Decenber 2023)
27 October 2028100 tonnes or more per yearCandidate list substances (as at 27 October 2026)
27 October 20301 tonne or more per year 

For more detailed information please contact us.