Only Representatives (ORs)

Non-EU manufacturers who export substances to the EU cannot submit REACH registrations, as they are based outside the EU. However, they can appoint an Only Representative (OR) to represent them in the EU. Non-EU formulators of mixtures and producers of articles can also appoint an OR; however, non-EU distributors cannot appoint an OR.

Only representatives must be :

• A natural person or legal entity established physically in the EEA
• Equipped with sufficient knowledge in the practical handling of the substances and information related to them
• Appointed by a mutual agreement with a manufacturer, formulator or article producer, established outside the EEA
• Responsible for complying with the legal requirements for importers under REACH, including those related to authorisation and restriction.

Only representatives can represent more than one non-EEA supplier, but must keep the information related to each of them separate.Once appointed, the OR takes on the role of importer, representing all the EU customers of the non-EU manufacturer. The OR completes the registration dossier on behalf of all 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 OR arrangement.

Further information, including Q&As on ORs can be found on the ECHA website.

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