REACH Only Representative

REACH requires companies that manufacture a substance in the EU or import it into the EU in quantities of 1 tonne or more per year to register it with the European Chemicals Agency (ECHA). Only legal entities established in the EU can register; however, non-EU manufacturers can appoint an EU-based Only Representative (OR) under REACH Article 8 to register on their behalf. In that case, their EU importers are regarded as downstream users and do not need to register. ECHA’s REACH and CLP for non-EU companies page provides official guidance.

Benefits of Appointing REACH Only Representative (OR)

Relieve your importers of their registration obligations and secure continued access to the EU market (many EU importers try to pass the registration burden on to their suppliers).
Avoid dependence on a single importer and keep market access if an EU importer stops trading.
Gain a competitive advantage over non-EU suppliers that have not appointed an Only Representative (OR).

Note: EU importers are exempt from REACH registration if an Only Representative has registered the substance on behalf of the non-EU manufacturer. However, importers must confirm that they are included in the Only Representative’s list of importers and that their tonnage and uses are covered. This is usually done by requesting a REACH compliance letter (certificate) from the Only Representative before placing products on the EU market.

Who Can Be Appointed as REACH Only Representative?

An Only Representative must be a natural or legal person established in the EU with sufficient background in the practical handling of substances and the related information, as required by REACH Article 8(2). More specifically, an Only Representative shall:

Our REACH Only Representative Services

We provide cost-effective Only Representative services and have represented many companies from Türkiye. If you are looking for a REACH only representative or wish to change only representative, please don’t hesitate to contact us for further advice.

What Do We Do as REACH Only Representative?

In according to Article 8 of REACH, OR is taking full obligations of importers under REACH, in which case importers will be regarded as downstream users (thus do not need to register). Those obligations include:

Keep the registration data submitted to ECHA via REACH-IT (company identity, annual tonnage, etc.) up to date
Represent your company in SIEFs and consortia and keep you informed of developments
Supply Safety Data Sheets, transmit them along the supply chain and inform you about updates
Communicate with EU importers and authorities and prepare the documents needed for REACH compliance
Keep an up-to-date list of importers and the tonnage covered for each; retain this information for at least 10 years and provide it to authorities on request
Fulfil further obligations such as registration, notification and authorisation (separate contract required)

How to Change REACH Only Representative?

Non-EU companies have the right to change their Only Representative if they are not satisfied. The change is made through a legal entity change in ECHA’s REACH-IT system, which transfers the existing registrations to the new Only Representative. This requires the cooperation and approval of the previous Only Representative. If the previous Only Representative does not cooperate, the new Only Representative may need to register again, which means additional cost and time.

Planning the new contract and the transfer process is important when changing your Only Representative. If your previous Only Representative does not accept the transfer, please contact us to discuss the options.