REACH Only Representative: What are the benefits of appointing an Only Representative for REACH?
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What are the benefits of appointing an Only Representative for REACH?
- Business continuity of non-EU manufacturer!
- There are basically only two ways to maintain your market for a substance imported into the EU within the scope of REACHregistration requirements:
- Importer registers (and pre-registers if he wishes to benefit from phase-in status)
- Only representative registers (/pre-registers)
If the importer registers: (less advantage for the Non-EU manufacturers)
- Each and every separate importer of the substance as such, in preparations or (where applicable) in articles has to register the quantity he imports. The importer “owns” the registration and can import the substance from multiple sources within the scope of his registration.
- If the exporting Non-EU manufacturer wishes to find a new/ additional importer, this new importer has to comply with the registration requirements of REACH and cannot benefit from a registration made by an existing importer of the Non-EU manufacturer.
If the only representative registers: (more advantage for the Non-EU manufacturers)
- The only representative takes on the responsibilities and is liable for fulfilling the obligations of importers under REACH for the quantities of substance(s) for which he is appointed and that are exported to the EU by the appointing Non-EU manufacturer.If he functions as OR for the same substance from different non-EU manufacturers, he has to register the volumes for each non-EU manufacturer, separately.
- The other importers of the substance from this specific Non-EU manufacturer become downstream users for the purpose of the REACH Regulation.
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