根据 CLP，再进口商有哪些角色和义务？

根据 CLP，再进口商有哪些角色和义务？

What roles and obligations do re-importers have under CLP?

根据 CLP 第 2(19) 条，再进口商被视为下游用户。因此，再进口商没有义务向 C&L 清单进行通知或根据 CLP 标题 II 进行分类，但也可以接管供应链中其他参与者已经根据标题 II 得出的分类。在任何情况下，再进口商都必须确保标签和包装符合 CLP 要求。请注意，再进口商要被视为下游用户必须满足某些条件。首先，再进口的物质必须在从欧盟出口之前进行注册。此外，该物质必须在同一供应链内再进口。第三，再进口商需要能够证明再进口的物质与最初出口的物质相同。最后，再进口商还必须能够证明其已根据 REACH 第 31 条或第 32 条获得相关信息。如上述任何一项条件不满足，则再进口商将被视为进口商。这意味着再进口商有义务对这些物质或混合物进行分类，并将相关物质信息通报给 C&L 清单。

According to CLP Article 2(19), a re-importer is considered a downstream user. Re-importers are therefore not obliged to notify to the C&L Inventory or to classify in accordance with Title II of CLP, but may also take over the classification derived in accordance with Title II already by another actor in the supply chain. In any case the re-importer has to ensure that the labelling and packaging is in accordance with CLP. Note that for a re-importer to be considered a downstream user certain conditions have to be fulfilled. First, the re-imported substance must have been registered before it was exported from the EU. In addition, the substance must have been re-imported within the same supply chain. Third, a re-importer needs to be able to show that the re-imported substance is the same as the one that was originally exported. Finally, the re-importer must also be able to show that he has been provided with the respective information in accordance with REACH Article 31 or 32. When any of the conditions mentioned above is not fulfilled, the re-importer is considered an importer. This means that he has the obligation to classify these substances or mixtures and to notify relevant substance information to the C&L Inventory.