Roles under REACH in brief

Under REACH, all ‘actors’ in the supply chain have a responsibility to ensure that they manufacture, place on the market or use substances in ways which do not adversely affect human health or the environment. Obligations under REACH are determined by the role of the actor in the supply chain: manufacturer, importer, only representative, distributor or downstream user.

Manufacturer / Importer

A manufacturer under REACH is considered to be any company manufacturing a chemical substance within the EU while an importer is defined as a company that imports a chemical substance from outside the customs territory of the EU. These actors are considered to be at the top of the supply chain and therefore have most of the responsibilities relating to the chemical that they introduce to the EU market. They must gather information on these substances and how they are being used and register any substance manufactured or imported into the EU at 1 tonne or more per year with the ECHA.

Did you know? A company purchasing chemical substances from within the EU is not an Importer but is considered a downstream user under REACH.

Only Representative (OR)

An Only Representative (OR) is an EU person appointed by the non EU manufacturer of a substance to represent them in relation to REACH. The OR, once appointed, must fulfil all the duties of the importer in relation to registration, information in the supply chain and communicating with EU customers.

Did you know? Once an OR has been appointed by a non-EU manufacturer to carry out the duties related to registration, all importers of the same non EU manufacturer are considered downstream users under REACH.

Downstream User

Those who buy their chemicals in Europe and use them in a professional capacity are considered downstream users under REACH. The main role of the downstream user is to ensure that substances are used in a manner that is safe in accordance with the suppliers guidelines

Did you know! A consumer is not a downstream user under REACH

Distributor

A distributor is any person that only stores and passes chemical substances onto third parties e.g. a retailer. The distributer has a duty to communicate information on substances within the supply chain and has an obligation to keep information relevant to those substances.

Roles under REACH in detail