ORs can submit group C&L notifications to ECHA
The European Commission has clarified that ECHA may allow third parties, such as Only Representatives (ORs) appointed under the REACH Regulation, to submit C&L notifications under Article 40 of the CLP Regulation. This is possible, provided that the importers remain responsible for the notification and the system is enforceable.
ECHA is adapting the submission interface in its IT system to indicate that third parties who are not themselves manufacturers or importers can also take over the submission of group notifications. Group notification can be done via REACH-IT. The relevant changes will be implemented with the forthcoming REACH-IT release scheduled for summer 2012. Guidance and other supporting documents will be updated in the following weeks.
If the C&L notification is submitted by a third party on behalf of a group of manufacturers/importers, the submitting company will need to be able to document that it has been mandated to act on behalf and in the name of the manufacturers/importers that are part of the group and that the manufacturers/importers acknowledge that they remain solely and fully responsible for fulfilling all their obligations associated with the notification. The documentation related to the creation of this group of manufacturers/importers together with the data and information on which the C&L is based, may need to be made available on request to the national Competent Authorities or to the relevant Enforcement Authorities.
* Notification to the C&L Inventory - Who?
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