The Blog

According to commission regulation, Only Representatives (ORs) of Non-EU manufacturers/formulators are required to identify the Non-EU manufacturer/formulator they represent in REACH-IT by 14 October 2022. The functionality for such action is available in REACH IT from 26 April, 2022. To fulfil this new requirement, ORs must have a separate REACH-IT account for each non-EU manufacturer/formulator they represent even if they are part of the same group – and submit the necessary registrations for each of them from the correct REACH-IT accounts.

It is important to highlight that one REACH-IT account can contain registrations from only one non-EU manufacturer/formulator.

Information to be provided by the OR:

According to ECHA’s website, Only Representatives need to provide following information in REACH-IT of the Non-EU manufacturer/formulator they represent:

• name , address, telephone number and email address;
• contact person;
• location of any production or formulation sites;
• national company identification numbers (if any)
• OR appointment letter
• Whether you want to disclose the name of the non-EU manufacturer in REACH-IT or not
• Company size (with supporting documentation)

What happens if you are an OR but also a manufacturer or an importer?

It is important to note that an OR cannot declare to be as well a manufacturer or importer in the same REACH-IT account. If this is your case, you must have a separate REACH-IT account covering manufacturing/importing activities and submit the necessary registrations from this REACH-IT account.

What are the roles that are not compatible within the same REACH-IT account?

• OR and Importer
• OR and Manufacturer
• OR and Manufacturer/Importer

How can Only Representatives prepare to fulfil this requirement?

1. Check if from your REACH-IT account you represent several non-EU manufacturers/formulators – If yes, then you are required to fix this situation as soon as possible as you must have a separate REACH IT account per non-EU Manufacturer or formulator. To solve this you need to transfer the registrations to the correct REACH-IT accounts.
2. Check if you are representing a Non-EU Manufacturer/formulator from several RECH-IT accounts – If yes, you are required to merge those accounts into one. Keep in mind that you should represent a non-EU Manufacturer/formulator from just one REACH-IT account .

More information on how to declare your Non-EU Manufacturers/formulators in REACH IT can be found here: https://echa.europa.eu/en/-/only-representatives-must-declare-their-non-eu-manufacturers