REACH Only Representative

REACH applies only to legal entities established in the European Economic Area. Companies based outside Europe may not directly fulfill any obligations under REACH. As a consequence, customers of a non-European supplier have to fulfill all obligations under the regulations of REACH as an importer – which is a distinct disadvantage in comparison to purchasing from a European manufacturer. However, non-EU companies may appoint a European-based Only Representative (OR) to take over the tasks and responsibilities for complying with the regulations pursuant to REACH art. 8. This can simplify access to the EEA market for their products, secure the supply and reduce the responsibilities for the European customer.


Read more about the ADVANTAGES of an Only Representative.


Only representatives have to be:

  • A natural person or legal entity established physically in the EEA
  • Equipped with sufficient knowledge in the practical handling of the substances and information related to them
  • Appointed by a mutual agreement with a manufacturer, formulator or article producer, established outside the EEA
  • Responsible for complying with the legal requirements for importers under REACH


The non-Union company has to inform the importer(s) within the same supply chain of the appointment of an only representative. These importers are then regarded as downstream users for REACH.


It will be the task of the only representative to comply with all the obligations with which the importers of your products would have to comply. This includes submitting a pre-registration and a REACH registration dossier for the substance imported into the EU to the European Chemicals Agency (ECHA) before the relevant deadlines expire. It will also be the task of the only representative to keep the information available and update on i) the quantities imported and ii) the importers covered by the appointment, as well as to iii) supply the latest update of the safety data sheet. The only representative must therefore have a sufficient background in the practical handling of substances and the information related to them.
Only representatives need to be able to document for the enforcement authorities that they have been appointed by your company and for which substance and volume the appointment applies. They may also indicate in the registration dossier by whom they were appointed. They need to be able to document that the non-European company has informed the importers who are covered and who may benefit from the only representative having fulfilled the importers’ obligations.


The REACH registration by an only representative can cover volumes of a substance imported into the EU both directly from non-EU manufacturers and via non-EU distributors or formulators. Thus, as long as the non-EU manufacturer can keep track and document the channels through which the substance or mixture is imported into the EU, the volumes can be covered by the only representative. Non-EU manufacturers can change their only representative.


If you wish to make use of the only representative mechanism, please contact us.