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Only Representative (OR) Services

A non-EU company cannot register substances under REACH but they can appoint an Only Representative (OR) who is legally responsible for ensuring its non-EU clients substances are compliant with REACH Regulation. The appointment of an Only Representative has many advantages for the non-EU manufacturer:

  • An independent third party takes on all obligations of the importers under REACH. The Importers then become downstream users.
  • If an importer registers a product the importing company will own the registration. It may then be more difficult for the manufacturer to expand or change the route to the European market. With an OR the non-European manufacturer owns the registration and can therefore export to as many different European importers as they want.
  • If an importer changes supplier the non-EU manufacturer may lose access to the European market.

For phase-in substances the Only Representative will make, subject to certain conditions being fulfilled, a late pre-registration to the European Chemicals Agency (ECHA). The submission of a late pre-registration permits a non-EU manufactuer to supply into the EU and take advantage of the extended registration deadline program. Subsequently the Only Representative undertakes all duties as are necessary to maintain REACH compliance, including documentation, record keeping and preparation and submission of a registration dossier.

For non phase-in substances the Only Representative will prepare an inquiry dossier and negotiate with ECHA or data holders to gain access to the data required to complete a registration. If any testing is prescribed by ECHA the Only Representative will organise and monitor this testing to ensure compliance. The Only Representative will prepare and submit the registration dossier to ECHA and will be the first contact for any communication from ECHA or Member State Competent Authorities.

In accordance with the requirement of the REACH Regulation, Article 8(2); ReFaC's technical support team is able to demonstrate many years of industry expertise in regulatory affairs and the safe handling of chemicals.

ReFaC offers the Only Representative service to assist non-EU chemical manufacturers to continue to supply chemical substances into the EU market or to their EU based distributors.

If you wish to discuss the Only Representative Service please contact ReFaC for an initial, confidential discussion.

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