Appointment of Only Representatives (ORs)
Non-EU manufacturers who export substances to Europe cannot register under REACH as they are based outside Europe. However, there is a facility that allows them to appoint an only representative (OR) to represent them in Europe. Once appointed, the OR takes on the role of importer, representing all of the EU customers of the non-EU manufacturer. The OR completes the registration dossier on behalf of all of the EU importers – who then become downstream users. Official appointment of the OR must be made in writing by the non-EU manufacturer, the EU importers must have confirmation of this appointment and that their tonnage is covered by the arrangement. The OR must have the necessary skills, resources and experience to complete the tasks.
Further details, including a set of Q&As on ORs can be found on the ECHA website.
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