REACH requires all companies manufacturing or placing a substance on the EU market in quantities of one tonne or greater per year to register that substance with the European Chemicals Agency (ECHA). For legal reasons, only companies with a legal entity in Europe are allowed to submit a registration; however, non-EU companies may opt for an Only Representative to register on their behalf.
The Benefits of Representative Services
- Non-EU companies can relieve each of their importers of the obligation to register their substance, ensuring continued market access for their substances in Europe.
- Non-EU companies can decouple their market access from that of their importers. Thus, they are free to expand their business and freely change and/or acquire additional importers within the EU, which otherwise could prove difficult under REACH.
- Continued market access should an EU importer cease trading.
- Anonymity (for both EU and non-EU companies if required).
Companies who first began manufacturing or placing phase-in substances on the European market in excess of one tonne per annum after December 1st, 2008, can benefit from an extended REACH registration deadline of May 2018 by submitting a late pre-registration for substances not exceeding 100 tonnes.
To do so, the company must submit a pre-registration within six months of first breaching the one tonne threshold and at least 12 months before the final registration deadline of 31st May 2018.
Companies who do not qualify for late pre-registration must follow a different process, for more information see REACH Registration and Inquiry.
The Only Representative Service allows non-EU companies to pre-register and register substances with ECHA. H2 Compliance assumes the non-EU company’s liability, tracks the client’s tonnage to ensure compliance as set out in REACH Article 8, acts as a communication point for downstream users’ queries, accepts an official role within the SIEF, and submits a technical registration dossier to ECHA if required.
Third Party Representative
Removes the burden of tracking registration and SIEF activities from EU Companies and allows them to remain anonymous within SIEF. This can be important if companies do not wish to disclose their interest in a substance to competitors.
Changing Your Only Representative
Under REACH, companies are allowed to change their Only Representative if unhappy or dissatisfied. If you would like to find out more about H2 Compliance being your Only Representative, contact us for more information.