Traders of 'pure' tin and tin in alloys
The REACH Regulation will impose certain duties on traders of tin metal. Traders of tin metal face various possibilities with the tin metal they buy:
Traders can buy their tin metal from a non-EU manufacturer that has registered their substance via an Only Representative, or from an importer that has already registered tin. In this case, their duties only extend to: passing the relevant information down the supply chain (usually in the form of a safety data sheet), and keeping records of the substances they buy (by documenting the registration numbers and suppliers of the substances they buy).
Alternatively, traders can import their tin metal direct from non-EU manufacturers who have not registered their substance via an Only Representative, or from warehouses holding non-registered tin metal. In these cases, the traders are viewed of as importers of tin metal and as such must register that tin metal with the Agency with the information requirements pertaining to the annual tonnage of the tin metal they are buying from those un-registered sources. If traders register tin metal, they will be able to buy their tin from any non-registered manufacturer and from any warehouse.
It is therefore imperative that traders think carefully about the supply of the metal they buy as this will have a direct impact on their obligations under REACH. The roles that traders choose to fulfil will also affect the proportion of tin metal, on the EU market, that is accessible to them.