According to the REACH Regulation, a manufacturer is defined as: 'any natural or legal person established within the Community who manufactures a substance within the Community' (Article 3(9)).
EU Manufacturers
All chemical manufacturers that are located in the EU and produce chemicals that come under the scope of the REACH regulation are obliged to register. The pre-registration period (1st June - 1st December, 2008) has ended so you should have pre-registered any substances that are under the scope of the REACh regulation by now. If you have not, we can assist you with late pre-registration.
The 2010 deadline has passed for those manufacturers that wished to register for >1000 tonnes per annum. The next step is for those manufacturers who intend to register 100-1000 tonnes and 10-100 tonnes per annum for the 2013 and 2018 deadlines respectively, to consider how they can do this in the most efficient and cost-effective manner.
Please This e-mail address is being protected from spambots. You need JavaScript enabled to view it for assistance with registration for the 2013 and 2018 deadlines.
Non-EU Manufacturers
Non-EU manufacturers also have to understand and comply with the REACH Regulation if they want to continue marketing their products in the EU. However, non-EU manufacturers cannot directly pre-register/register the substances that they export into the EU. Such registration can only be made by their own agent (i.e. EU company), EU importers or by the appointment of an Only Representative (OR). If you allow your EU importers to register, the control of the supply chain will rest with them i.e. you may only sell your products through EU importers who have registered, which can limit your market. If you register yourself, through an Only Representative (OR), you remain in control of your supply chain at all times.
The benefits of registering through an Only Representative:
- The manufacturer does not need to have its own company in the EU.
- The manufacturer has direct control over the registration process of its substance(s).
- When an OR is appointed, an EU importers is relieved of their REACh obligations. This may make your manufacturing company a more attractive trading partner.
Please This e-mail address is being protected from spambots. You need JavaScript enabled to view it for our Only Representative services.