EU REACH Regulation Only Representative

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REACH Only Representative (OR)

‘The OR provides a stepping stone into an otherwise inaccessible market for non EU companies’

All companies manufacturing or placing a substance on the EU market in quantities greater


than 1t/year must register the substance with the European Chemicals Agency (ECHA). As
only companies with a legal entity in Europe are allowed to submit a registration non-EU
companies may appointing an EU-based Only Representative to register on their behalf, in
which case their importers will be regarded as downstream users and do not need to do
registrations.

Benefits of Appointing REACH Only Representative (OR)

 Relieve importers of their obligations to register and obtain continued market access in the
EU
 Avoid dependence on a single importer and keep market access should one EU importer cease trading;
 Gain advantages over other non-EU suppliers who do not appoint OR to register their substances;

Importers whose suppliers have registered are REACH exempt, however, they need to confirm with their suppliers' OR that they
are included in the inventory of importers and their tonnage/ uses are covered by the OR. Ask for REACH Certificate of
Compliance from the OR of your suppliers before you put chemicals on the EU market.

What are REACH Only Representative requirements?


What does REACH Only Representative do?

 Must be a legal entity based within Europe  Maintain pre-registration data(company identity, annual
 have the ability/expertise to understand and implement the tonnage, etc ) submitted to ECHA through REACH-IT;
responsibilities of an importer that only representatives take
 SIEF/Consortium representation and participation
on under the provisions of REACH (pre-registration,
registration, authorization, etc);  Supply Safety Data Sheets along the supply chain and
 be capable of keeping an up-to-date list of EU importers keep information on the supply of latest SDS updates
within the same supply chain of the non-EU manufacturer it  Communicate with EU importers and regulatory
represents; authorities and issue necessary documents to ensure
 have a record-keeping system with data on imported REACH compliance;
quantities and all uses covered;
 Update inventory of importers list and the tonnage
 be capable of keeping the latest information on the supply
covered for each of these importers (10 years) and
of safety data sheets
provide it to enforcement authorities upon request;
 Submit Registration, notification and authorization of
substances
Can I Change REACH Only Representative? Why Choose OR with CIRS

Yes, if you are unsatisfied or wish to transfer OR you may. We are the largest REACH Only Representative and have
Non-EU companies have a right to change only representative represented over 2,400 non-EU companies worldwide. If
if they are unsatisfied. If the non-EU manufacturer nominates you are looking for a cost-effective REACH only
a new only representative the newly appointed OR can benefit representative or wish to change only representative,
from the pre-registration done by the previous representative
please don't hesitate to contact us for further advice
if ECHA is informed about the change.
Contact morgan@cir-reach.com

CIRS Ireland -Singleton House, Laurence Street, Drogheda, Co. Louth, Ireland
Tel: +353 41 9806 916 | Fax: +353 41 9806 999
www.cirs-reach.com

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