By appointing an EU REACH Only Representative, manufacturers of substances, mixtures, or articles located outside the European Union can fulfil their registration and compliance obligations under the EU REACH Regulation (EC) No 1907/2006. This allows non-EU companies to place their products on the European Union market without burdening their importers with registration costs.
Roles and Responsibilities of an EU REACH Only Representative
- Legal Liaison: Acts as the official point of contact between the non-EU manufacturer and the national market surveillance authorities within the EU (e.g., Ministries of Health & Environment).
- Documentation: Maintains copies of the manufacturer’s technical documentation (e.g., technical dossier, Declaration of Conformity, certificates) and provides them to competent authorities upon request.
- Compliance Verification: Ensures the Declaration of Conformity and technical documentation are accurately prepared and that appropriate conformity assessment procedures have been applied.
- Incident Reporting: Assists in reporting any incidents related to the product to the relevant EU authorities.
- Labelling: Ensures that the name and address of the Only Representative are included on the product, its packaging, or accompanying documentation.
- Market Surveillance: Cooperates with surveillance authorities in case of non-compliance or safety issues and facilitates access to product samples.
Our EU REACH Only Representative Services Include:
- REACH Registration & Compliance
- Supply Chain Management for Lead and Co-registrants
- Data Management for Lead Registrants on Data Sharing Process
- LoA Purchasing Process for co-registrants
- SIEF/Consortium Representation
- Post-Registration Support
Chemleg Europe Offers:
- Expertise in REACH regulatory compliance
- Cost-effective and reliable representation
- Secure handling of confidential business information
- Ongoing support for regulatory updates and inquiries
Get in touch to ensure seamless EU market access with our Only Representative services.
Frequently Asked Questions
Who is required to appoint an Only Representative?
Manufacturers located outside the European Union (e.g., in Turkey) who export chemicals to the EU are required to appoint an Only Representative. Otherwise, each EU importer becomes individually responsible for REACH compliance.
What happens if I don’t appoint an Only Representative?
Each EU-based importer will become a separate REACH registrant, which increases the risk of loss of control, disclosure of trade secrets, and potential legal non-compliance. It may also hinder your access to the EU market.
I have a distributor in the EU. Do I still need an Only Representative?
Yes. Distributors do not assume REACH obligations. To maintain direct access to the EU market, control compliance duties, and protect trade secrets, appointing an Only Representative is essential.
Do I need additional services besides Only Representation?
Usually, yes. Services such as SDS preparation, registration based on tonnage band, classification and labelling, and regulatory consulting are often required for REACH compliance.
If I have multiple importers in the EU, do I need to register separately with each one?
No. Chemleg registers the substance once on your behalf as the Only Representative. This registration can then be used by all your EU importers, saving both time and costs.
Can I appoint different Only Representatives for each substance?
While technically possible, it is not recommended. It may create confusion in the supply chain, communication gaps, and dispersed legal responsibilities. It is best to manage all REACH processes through a single representative.
I started sending a registered substance to another EU country. Do I need to take additional steps?
No. A REACH registration is valid throughout the European Economic Area. However, updates are required in case of tonnage increases or changes in use conditions. Chemleg monitors and updates this on your behalf.
Is joining a consortium mandatory?
No, but it often offers cost benefits. Chemleg analyses consortium options and recommends the most suitable strategy for you.