Your REACH Only Representative for non-EU substance manufacturers
A REACH Only Representative (OR) is a natural or legal person established in the EU, appointed in writing by a manufacturer of a substance outside the EU, to fulfil the registration obligations of importers under Article 8 of Regulation (EC) No 1907/2006 (REACH).
If your company is established outside the EU and manufactures a substance (on its own, in a mixture, or intended to be released from an article) that is imported into the EU at 1 tonne per year or more, someone in the supply chain must register it with the European Chemicals Agency (ECHA) before it can be placed on the EU market - "no data, no market." Instead of leaving each EU importer to register separately, Article 8 lets you appoint an Only Representative established in the Union to register the substance once, in its own name, on your behalf. Once appointed, your EU importers are reclassified as downstream users rather than importers, and the registration obligation - and the underlying composition and safety data - sits with your Only Representative rather than being scattered across your customer base.
The Only Representative does not manufacture, formulate or sell the substance, and does not take over the manufacturer's responsibility for the accuracy of the underlying safety data - that data still has to be correct and defensible.
Being appointed as Only Representative and actually building a REACH-compliant registration dossier are two different pieces of work. This is exactly why we offer OR appointment and registration support as a combined service - see Registration & dossier support for the IUCLID and data-sharing work that sits behind the mandate.
Under REACH Article 8, the Only Representative takes on the registration obligations that would otherwise fall on EU importers of the substance: registering with ECHA in REACH-IT, keeping up to date information on quantities imported and customers, and providing that information to enforcement authorities on request.
Two reasons dominate. First, if several EU importers each try to register the same substance separately, the manufacturer's EU customers face duplicated cost and delay, and any one importer's failure to register blocks that customer's supply. Second, registration requires disclosing the substance's exact composition and safety data - most manufacturers would rather share that once with a single trusted Only Representative than with every EU customer who imports their substance.
Only if the substance (on its own, in a mixture above the relevant concentration, or intended to be released from an article) is manufactured or supplied into the EU at 1 tonne per year or more and no EU-established entity already registers it. Below that threshold, or where EU importers already register independently, an OR is not legally required, though many manufacturers still use one to keep formulation data confidential.
The Only Representative is the EU-established legal role appointed under Article 8, holding the mandate and the registration in its own name in REACH-IT. Registration support is the technical work of preparing the IUCLID dossier, sourcing or generating the required data (Annexes VII-X depending on tonnage), and coordinating data-sharing with other registrants of the same substance (SIEF). We offer both together for manufacturers who need registration built, not just held.
No. Registration under REACH and notification under the CLP Regulation (EC) No 1272/2008 are separate obligations. Most manufacturers placing a classified substance on the EU market need both a REACH registration and a CLP notification to ECHA's Classification and Labelling Inventory.
Note: This page provides general information, not legal advice. Specific obligations depend on your substance identity, tonnage band and supply chain.
Tell us your substance, tonnage band and where your company is established. We will qualify the next step before any mandate is signed.