EU REACH: You must disclose your Non-EU manufacturers/formulators in REACH-IT by 14.10.2022

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:

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