REACH Regulation (EC) No 1907/2006 affects you if you manufacture or export more than one tonne of chemical substance as such or in product(s) (mixtures, articles) to the EU per year.

CHEMENTORS helps customers around the world with EU REACH compliance and certification services, and we are fully qualified to act as your REACH Only Representative (OR) for the European market.

EU REACH consulting & Only Representative Service

We assist customers around the world with EU REACH services. We are fully qualified to act as your REACH Only Representative for the European market. Contact us and let our experts handle your EU REACH matters.

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Rebecca Karjalainen

Customer inquiries
Phone +358 44 974 0601
rebecca.karjalainen@chementors.fi
Finnish | English | French

    Our EU REACH services

    We take care of the complete REACH registration process from scratch or certain parts of it based on our client’s needs. Our ultimate mission is to enable our clients to focus on their own business while leaving all REACH issues to us on a turnkey basis.

    Our REACH team consists of specialists with backgrounds in chemistry and toxicology, and a profound understanding of EU REACH regulations. Since 2012, we have successfully worked on numerous REACH registrations for different substances in various product types.

    We customize our services case by case based on the nature of clients’ projects and their needs.

    Chementors

    We offer a wide range of EU REACH services

    We also provide partial REACH services as per the client’s preference. It could be, for example, analyzing a client’s regulatory obligations under REACH for a given manufacturing/importing model, consulting testing strategies, or handling the inquiry submission phase only.

    accessing regulatory requirements

    analysis of data gaps

    communicating with the Lead Registrant for the right to use data

    planning tests with laboratory units

    preparing dossier for REACH inquiry submission

    preparing dossier for REACH registration submission

    following up for ECHA notifications

    updating the dossiers

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    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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    EU REACH Experts

    In addition to the registration tasks, we have experience with PPORD notification and EU-REACH compliance declaration.

    As an EU legal entity, we have been acting as an Only Representative for many non-EU manufacturers and exporters from overseas. We are also a member of the only representative organization (ORO).

    We offer a wide range of services optimized to client’s needs, including but not limited to:

    EU REACH Registration services for both joint submissions and new submissions

    EU REACH Inquiry submission services

    EU REACH PPORD notification services

    EU REACH dossier update

    EU Only Representative

    EU REACH compliance consulting & declaration

    Testing strategies for EU REACH registrations

    EU REACH regulation trainings

    The European Chemicals Agency (ECHA) has its headquarter in Helsinki, Finland, where our office and most of our experts are based. Our REACH team can discuss with ECHA experts face to face on confidential customer issues smoothly and efficiently. Another advantage is the possibility to communicate with Finnish experts in their language.

    eu reach only representative services

    REACH Only Representative

    According to the regulation, legal entities established outside the EU do not have a duty under REACH.

    Therefore, to export their substance as such, or in a mixture/article to the EU, the registration of that substance should be done either by the importers or by the Only Representative (OR).

    The OR is a legal entity established in the EU that is appointed by non-EU entities to fulfil registration obligations.

    The main difference in terms of trading activities is that when the substance is registered by an OR, the non-EU suppliers can actively sell their substance to multiple importers in the EU.

    This proactiveness grants wider choices and smoother ways to the EU market and enhances competitiveness. Otherwise, the business would be limited only to importers who have done the registration beforehand.

    “REACH registration cannot be done by non-EU entities. Instead, the non-EU suppliers can appoint an EU-based Only Representative to register the substance”

    Chementors in numbers:

    Since 2012, we have successfully completed more than 100 REACH registration projects including PPORD for clients in more than 15 countries in the world.

    We also have acted as the Only Representative for several companies established outside the EU.

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    What is the EU-REACH regulation?

    REACH stands for Registration, Evaluation, Authorisation, and Restriction of Chemicals, chemical legislation developed by the European Union which came into force on 1 June 2007.

    EU-REACH was established to enhance the protection of human health and the environment from chemical-related risks.

    This regulation encourages innovations in chemical industries to produce substitutions for safer chemicals and greener manufacturing processes. In this way, REACH has been in line with and contributed significantly to the Circular Economy model.

    Through its principle of promoting alternative test methods whenever applicable, REACH also helps improve animal welfare. In terms of trading, REACH compliance opens smooth access to the EU market and hence levels up the business competitiveness for companies.

    Scope of REACH

    In principle, REACH regulations apply to the manufacture, import, placing on the market, and use of chemical substances on their own, in mixtures, or articles in the quantities of one tonne or more per year.

    All chemicals, with certain exceptions, are subject to regulatory obligations under REACH including those used in industrial sectors and daily life.

    “To be placed on the EU market, substances on their own, in mixtures, or in articles being manufactured or imported in the quantities of one tonne or more per year must be registered”

    Who must register under REACH?

    Depending on the activities in the supply chain, a legal entity may have separate roles under REACH. It is also possible that one entity would play multi roles, such as both manufacturer and importer roles, for the same substance.

    Therefore, it is of importance for companies to precisely determine their roles for each substance to fully abide by the corresponding obligations set to the role(s).

    REACH regulation lays down the registration obligations to the following actors:

    EU manufacturers and importers of substances as such or in mixtures in quantities of one tonne or more annually

    EU manufacturers and importers of articles if the article contains a substance in quantities over one tonne annually and the substance is intended to be released under normal or reasonably foreseeable conditions of use

    Only representatives who are established in the EU and appointed by companies established outside the EU fulfill the registration obligations of importers.

    PPORD

    In line to promote innovation, REACH sets exemption conditions for substances intended to be used for product and process-oriented research and development (PPORD).

    Such substances can be manufactured or imported at above one tonne per annum while being exempted from the obligation of registration for a period of five years.

    To be granted such exemption, companies are obliged to submit a PPORD notification to ECHA. PPORD notification is also subject to specific requirements on which information must be included in the submission.

    The submission shall be accessed by ECHA and certain conditions to that PPORD exemption could be imposed.

    Our EU-REACH registration process

    1. Understanding our client's needs

    2. REACH inquiry to ECHA

    • Contacting the consortium/lead registrant for substance identification profile

    • Analyzing available substance identification data

    • Planning the lab tests to fulfill the data gap

    • Compiling IUCLID dossier for the inquiry

    • Submitting the inquiry dossier

    • Getting ECHA's decision: a joint submission or new submission

    3. REACH registration to ECHA

    • Contacting the consortium/lead registrant for substance identification profile

    • Analyzing available substance identification data

    • Planning the lab tests to fulfill the data gap

    • Compiling IUCLID dossier for the inquiry

    • Submitting the inquiry dossier

    • Getting ECHA's decision: a joint submission or new submission

    Product categories

    We have been doing the REACH registrations for substances in mixtures from various industrial areas such as:

    eu reach product category registration

    adhesives and sealants

    air care products

    construction products

    biocides

    detergents and cleaning products

    fuels

    fragrances

    paints and coatings

    personal care products

    products for animal

    pulp and paper

    textile and garment treatment products

    surface treatment products

    FAQs

    REACH stands for Registration, Evaluation, Authorisation, and Restriction of Chemicals.

    REACH lays down obligations to legal entities established in all 27 member states of the European Union and the other Member States of the European Economic Area namely Norway, Iceland, and Liechtenstein.

    List of countries where EU-REACH is applied: Austria, Belgium, Bulgaria, Croatia, Republic of Cyprus, Czech Republic, Denmark, Estonia, Finland, France, Germany, Greece, Hungary, Ireland, Italy, Latvia, Lithuania, Luxembourg, Malta, Netherlands, Poland, Portugal, Romania, Slovakia, Slovenia, Spain, Sweden, Norway, Iceland, and Liechtenstein.

    No, it is not. EU REACH does not apply to substances that are manufactured in or imported to Great Britain (i.e., England, Scotland, Wales). Instead, companies should comply with the UK-REACH. For companies that are established outside Great Britain (GB), registrations can be done via the GB-based Only Representative.

    No, they are not. There are fundamental differences between REACH and ROHS. ROHS, standing for Restriction of Hazardous Substances, is an EU directive on certain substances which are present in electronic products.

    REACH, on the other hand, is an EU regulation laying down registration obligations to all chemicals which are present in a product in the quantities of one tonne or more per annum. Generally, if a product is ROHS-compliant, the product still must fulfill REACH registration obligations before being placed into the market, if such product falls into the scope of REACH.

    Yes, we do. We are experienced in organizing REACH training compliance processes for private companies as well as for state-own entities. Depending on the customer’s needs and roles in the supply chain, the training topics & contents could be customized, for example:

    • Understanding REACH regulation
    • Working with IUCLID & REACH-IT system
    • Preparation of REACH registration dossiers
    • Preparation for PPORD notification

    to name but a few.

    We aim to provide both general views of the process and key relevant points to customers’ projects. The training can be conducted onsite or online.

    It is correct that to export the chemicals to the EU market, the substance in quantities of one tonne or more per year must be registered beforehand.

    The registration cannot be done by the non-EU companies, but by (1) the EU importers or (2) the EU-based Only Representative.

    • In case (1), the non-EU companies can only trade their chemicals to a limited number of importers who have registered these chemicals under REACH.

     

    • While in case (2), the non-EU suppliers can appoint an EU entity who acts as their Only Representative to fulfill the registration obligations for their chemicals. This legal compliance brings significant competitiveness to the non-EU supplier as they can proactively promote and sell their chemicals to various importers in multiple EU countries.

    Only Representative is one of our key services. We are fully qualified to act as your REACH Only Representative for the European market.

    The information requirements in REACH registration depend significantly on the annual tonnage band which is the sum of annual manufactured and imported quantities. There are four tonnage bands under REACH: 1 to 10 tonnes, 10 to 100 tonnes, 100 to 1000 tonnes, and 1000 or more per year.

    The higher the tonnage band is, the greater amount of data would be needed. For instance, a Chemical Safety Report should be submitted if the substance is manufactured or imported in quantities of more than 10 tonnes annually.

    Therefore, it is important to determine the tonnage band correctly.

    With Chementors, you can rest assured that you are always complying to the highest standards and best EU REACH practices.

    Contact us for your REACH NEEDS

    Customer inquiries


    Phone +358 44 974 0601
    Address: Chementors Oy, Smart Chemistry Park, Raisionkaari 55, FI-21200, Raisio, Finland
    Email: rebecca.karjalainen@chementors.fi
    Finnish | English | French