Cosmetics and DGSA Specialist
Phone +358 10 504 5860
satu.salomaki@chementors.eu
Finnish | English
Companies outside of Europe need an EU REACH Only Representative (OR) to handle their EU REACH matters.We are fully qualified and experienced to act as your EU REACH Only Representative for the European market.
We offer a comprehensive approach to meet all of your EU REACH registration and Only Representative needs.
Contact us and let our experts handle all your REACH matters as your EU REACH Only Representative.
According to EU REACH Regulation (EC) No. 1907/2006, the registration must be done by EU manufacturers, EU importers, or EU Only Representatives (OR). Non-EU companies cannot make the registration.
Instead, non-EU legal suppliers who manufacture a substance on their own, in mixtures, or articles, formulate a combination, or manufacture a product imported into the EU market, can appoint an EU-based entity as their Only Representative to conduct the registration for their chemicals.
With this model, the Only Representative shall fulfill all REACH obligations of importers, and the importers shall become downstream users in the registration according to the regulation.
Chementors, with a legal entity in Finland, is experienced in acting as Only Representative for companies established outside the EU.
In short, in compliance with Article 8 of the REACH Regulation, a qualified Only representative must be:
“Non-EU entities cannot do REACH registration. The best choice for them would be appointing an EU-based Only Representative. Chementors offers qualified OR services.“
Via the Only Representative model, non-EU manufacturers can proactively promote and sell their chemicals to various importers in multiple EU countries instead of passively to a limited number of importers who have already made the REACH registration for the substances.
By having an OR to take care of all REACH legal obligations, time and resources could be saved while access to the EU market for products is simplified and widened. This allows non-EU companies to secure their supply and maintain competitiveness.
This OR practice also brings benefits to importers as their REACH responsibilities would be reduced remarkably. In fact, EU importers usually look for non-EU suppliers who have already registered their substances and are capable of maintaining the REACH compliance matters at all times.
Chementors with a team of competent and experienced experts has been acting as an OR for different non-EU entities. Operating on a one-stop service model, we take care of and handle all REACH obligations.
As an OR will be the one who processes all required data, handles REACH registration, and manages post-registration obligations, establishing an OR partnership is therefore critical to be sure that the REACH compliance status of the products is well taken care of at all times.
There are some common challenges and risks associated with REACH Only Representatives:
Choosing a good Only Representative is important. Chementors is a legally compliant and competent OR.
Phone +358 10 504 5860
satu.salomaki@chementors.eu
Finnish | English
Phone +84 39 6169 628
mi.nguyen@chementors.eu
English | Vietnamese
Phone +358 10 504 5862
prasanna.sakha@chementors.fi
English | Nepalese
Phone +358 10 504 5861
jan.nylund@chementors.eu
Finnish | Swedish | English | German
Chementors
Chementors, with its headquarters in Finland, is an EU-legal entity. We are also a member of the Only Representative Organization (ORO) and are approved by the REACHReady organization. If you are a non-EU manufacturer, we can legally represent you as an OR for your REACH registration.
Furthermore – The European Chemicals Agency (ECHA) has its headquarters in Helsinki, Finland, where one of our offices and most of our experts are based.
Our REACH team can discuss confidential issues with ECHA experts face-to-face smoothly and efficiently. Another advantage is the possibility of communicating with Finnish experts in their language.
We have several OR customers around the world; please see an example Case Study here. We have also accomplished many REACH registrations for non-EU manufacturers.
Legal entities established outside the EU who manufacture a substance on its own, in mixtures, or articles, formulate a mix or manufacture an article placed on the EU markets.
Legal entities established in the EU who should be competent in chemicals and REACH regulation to handle the whole REACH registration and follow-up process can be appointed as EU REACH Only Representatives.
Chementors’ Only Representative responsibilities are the following:
The REACH process continues even after the completion of the registration. This applies to all parties involved in REACH and not just the OR.
The exposure scenarios, Chemical Safety Assessment (CSA), and Chemical Safety Report (CSR) are ongoing ‘live’ documents that need updating with new test data or new exposure details if necessary. The safety data sheet is also a live document that would need an update and revision when required by the regulations.
Annual data on importing volumes and downstream users must also be updated in the system. In addition, from time to time, there are critical notifications and alerts from the European Chemicals Agency (ECHA) or from the consortiums on the registration system that require confirmations or further actions without delays from the registrants.
Therefore, the registration page should be taken care of to stay compliant. As an Only Representative, Chementors is here to assist you.
Generally, an OR will take care of some main tasks as follow:
Yes, it can. It is legally allowed under the REACH Regulation that an OR can represent more than one non-EU supplier.
There is no definite frequency when an OR should communicate with ECHA. In short, communication is often needed:
Yes, you can. Changing legal entities is allowed by the EU REACH regulation. Therefore, non-EU enterprises can change their OR following a process well guided by ECHA.
REACH regulation allows changing the legal entity, for instance from OR to another appointed EU company, to manage the registration on REACH-IT, in the same process as the above case, while keeping the registration intact. In other words, there is no re-registration when switching the legal entity.
The cost of Only Representative Service depends on the substance, tonnage band, and the number of importers. OR fee is charged yearly basis for every calendar year. The introductory prices are much less than 1000 € / year, up to 2000 € / year, depending on the above matters. Please get in touch with us for an exact quotation of OR fees for your substances.
Choose an OR, who
Chementors is fully qualified and respected OR in Finland and Europe.
Here are some practical tips for non-EU enterprises on choosing a qualified EU REACH Only Representative.
Select an OR who is a natural person or legal entity established physically in the EU, as per the requirement set in Article 8 of the REACH Regulation.
Choose an OR service provider who possesses in-depth expertise in chemistry and years of experience in the REACH compliance process. The OR should have a deep understanding of and be well familiar with the REACH terms and conditions, its requirements, the whole registration process, and all post-registration works.
It is highly recommended to select providers who have been in the industry for a long time and have a proven track record of successfully representing non-EU suppliers in the REACH process.
Make sure that the OR is qualified and accredited to provide the services. Do check if the OR has a team of competent specialists who possesses relevant background, expertise, and experience to handle all OR tasks.
Effective communication is critical for successful cooperation and long-term partnership. Do consider OR candidates that are responsive, transparent, and capable of providing regular updates on the registration and other OR tasks.
It is efficient to work with an OR who is fluent in English and other relevant languages to avoid misunderstandings and communication barriers.
More crucially, to ensure the quality and compliance of REACH works, it is strongly recommended to select an OR who is competent enough to use precise REACH legal terms and scientific phrases.
Go through the service details provided by the OR to make sure that they meet the project’s needs. It is better not to select providers that only offer a one-size-fits-all solution. Each project often has its unique characteristics and specific needs. Therefore, a wide range of services with tailored solutions would be preferred. A prospective OR should be the one who could provide an OR service contract with clear and lawful terms and conditions.
In addition, compare the pricing structure of different OR candidates and choose the one that brings good value for money.
Check the references and reviews of the OR from their previous and current clients. This practice would bring an idea of the reliability, competence, and professionalism of the OR. An OR with positive feedback and recommendations would be a prospective option to consider.
In short, selecting a competent EU REACH Only Representative is one of the critical steps for ensuring REACH compliance and avoiding legal and financial issues. Non-EU suppliers should therefore make an effort to ascertain that their future OR partner is competent and reliable.
It is recommended to cooperate with an OR having extensive experience and expertise, relevant qualifications and accreditations, excellent communication and language skills, a wide range of services with tailored solutions, and good value for money. Also, do check the references and reviews to learn about the reliability and professionalism of that OR.
Choosing an Only Representative with the cheapest offer might sound like a good idea at first glance, but it could cost more in the long run if that OR does not have the relevant and sufficient expertise.
It is advised to check the OR’s qualifications, experience, and references before making the decision based solely on price.
Not verifying the experience and competency in REACH compliance of the OR candidate could lead to low-quality REACH dossiers, errors and delays in the registration process, delays in acting with post-registration requests from the authority and consortium, or more severely, a violation of the REACH Regulation.
It is a good practice to always check the OR’s track record in successfully representing non-EU enterprises in REACH compliance.
Communication barriers due to language or cultural differences could cause misunderstandings, delays, or errors in the REACH compliance process. Working with an Only Representative who is excellent in language skills and proactive in communication would be a good move.
Forgetting to verify the references and reviews of the OR candidates could end up with selecting a provider with a poor track record or reputation. Before making a decision, it is helpful to check feedback from the providers past and current clients.
An overly general offer can lead to misunderstandings about the scope of services, responsibilities, timeline, and pricing structure. Asking for a detailed offer and service contract is highly recommended.
Selecting an Only Representative who provides a limited range of services may result in a need to hire some other service providers to manage other tasks in the REACH compliance process. This would eventually cause additional costs, huge delays, and extra workload.
A good practice is to cooperate with an OR who has a wide range of services and can handle all your REACH compliance needs.
Avoiding these common issues would bring greater chances of having a high-quality Only Representative who is competent enough to effectively assist non-EU suppliers in achieving and maintaining REACH compliance status for their products.
More than a decade in the industry, Chementors has been actively representing companies established outside the EU. We are a qualified EU REACH Only Representative who meets all required and necessary criteria:
We are here to assist you!
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Chementors Ltd | Finland | Hong Kong | Vietnam | info@chementors.fi
Please note that our team will be on annual leave from 21st to 29th December. During this time, response times may be longer than usual.
We appreciate your patience and will get back to you as soon as possible.
Wishing you a wonderful holiday season!
Best regards,
The Chementors Team