EU REACH Only Representative Services

The import of chemicals into the European Union is regulated by the Registration, Evaluation, and Authorization of Chemicals (REACH) Regulation (EU Regulation No. 1907/2006).

According to the EU REACH regulation, registration must be made when manufacturing, importing, placing on the market, and using substances on their own, in mixtures, or in articles in quantities of one tonne or more per year.

Rebecca Karjalainen

Customer inquiries
Phone +358 44 974 0601
[email protected]
Finnish | English | French

    Why appoint an EU-based Only Representative?

    According to EU-REACH regulation, the registration must be done by EU manufacturers, EU importers, and 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.

    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.

    “Non-EU entities cannot do REACH registration. Instead, they should appoint an EU-based Only Representative.”

    Chementors

    Why Chementors as your EU REACH OR?

    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.

    We are experts in EU REACH matters and can act as your REACH Only Representative in Europe. Let us help you manage the complex requirements of EU REACH compliance.

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    Who needs an Only Representative?

    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.

    Who can be appointed as EU REACH Only Representative?

    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.

    Our REACH Only Representative services

    Chementors’ Only Representative responsibilities are the following:

    • Accepting the role as an OR following the appointment by the supplier
    • Setting up a REACH-IT account and submitting a REACH inquiry and REACH registration dossier
    • Taking official roles in the Substance Information Exchange Forums (SIEFs)/Consortiums
    • Establishing and agreeing on testing strategies
    • Determining and agreeing on hazard assessment for each registration
    • Assessing and agreeing on data gaps
    • Compiling and agreeing on registration details
    • Negotiating contractual details
    • Organizing the preparation/updates of the Chemical Safety Report (CSR)
    • Organizing tests, monitoring laboratory work, and interpreting test results
    • Analyzing substance identity and agreeing on Substance Identity Profile (SIP)
    • Compiling the registration dossier
    • Assessing and agreeing on the content of safety data sheets (SDS) to be consistent with registration details
    • Identifying and agreeing to cooperate with importers
    • Monitoring supply patterns (import volumes and SDS check with each importer)
    • Communicating with importers and downstream users on certificates, volumes, uses, regulatory updates etc.,
    • Checking risk management measures which are being communicated in the supply chain
    • Considering exposure scenarios for downstream users in the supply chain
    • Cooperating with the authorities
    • Monitoring communication, messages, and alerts from the authorities

    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.

    The process to appoint Chementors as your Only Representative:

    Chementors checks clients' substance information and requests tonnage band for REACH registration costs, timeline, and process. Determining the OR yearly fee cost.

    Chementors provides OR service quotation and REACH registration quotation for the client.

    Once the quotation(s) is/are accepted, possible OR legal entity change will be handled by Chementors.

    Sign the Only Representative Service Agreement with the substance manufacturer (s).

    Chementors will handle all REACH registrations according to the agreed quotations with separate REACH Service Agreements.

    FAQs

    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

    • meets all legal requirements
    • knows the whole REACH process
    • also takes 100 % care of the technical registration work
    • has a transparent step-by-step process
    • provides a one-stop service to handle everything 
    • is a member of the Only Representative Organization (ORO)

    Chementors is fully qualified and respected OR in Finland and Europe.