Conflict Minerals - Tin Suppliers CMRT

Thanks so much for your replies. I've advised the company doing REACh compliance for our customer that I found this on the ECHA site:

You do not need to register if you only:

• distribute a substance: you store and place substances on the market, on their own or in mixtures, for third parties.

However, they are still requesting we complete the distributor reporting (We are a simple buy/resell distributor, no testing/assembly). None of the products we sell are above the threshold. I can get a listing of components we sell to each customer, but do I solely determine which parts have the 3TG content from my suppliers?

Again, I thank you greatly for your help!!!!

SpinDr99 said:

We are a simple buy/resell distributor, no testing/assembly

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Many distributors (US-based) that we work with do not consider it their responsibility to provide REACH declarations; instead they refer us to the manufacturers of the products they distribute for that information. Often, the distributors only have a Yes/No value for the REACH compliance of each product, which they get from the product manufacturers; the distributors rightly don't want to take on any liability.

So when completing template 6.10, am I correct in assuming that this is part(s) specific? First the Product List is completed for however many part numbers are being reported, then I go back to the Smelter tab and then the Declarations? I have one supplier who has a blank Product list, with several smelters and their information as well as information they're reporting in the Declarations tab, using the template in generic terms or as a "family" of products. It almost seems that the template works right to left. There doesn't seem to be anywhere but the Cove for guidance.

You guys are the best!!

Tagin said:

For your situation, you would usually do a single company-level CMR, which can be given to all customers.

Note that your CMR is a "best-effort" declaration. One of the questions on the CMRT asks: what percentage of suppliers have responded to you? So, while it would be nice for it to be complete, its not required, unless you have a customer that is an absolute stickler.



Cobalt is starting to become a fashionable thing to ask for:
Cobalt Reporting Template

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So there would be no part numbers listed?