REACH Non-EU Companies

We have a wealth of experience in helping companies that export chemicals, raw materials, articles or even finished goods to the EU to understand and fulfil their REACH obligations.

Chemicals imported into the EU, either in mixtures (e.g. paints, cosmetics, intermediates, polymers), finished products (e.g. clothes or plastic goods) or articles containing substances intended for release (e.g. scented candles) must have been have pre-registered (or registered).  You will therefore need to be involved in the registration under REACH in order to ensure that trade can legitimately continue in the EU.

As a non-EU manufacturer you cannot be actively involved with the REACH process unless you appoint an Only Representative (OR) to take over the responsibilities of REACH from your importers. This means your importers and customers no longer need to be involved in the registration process - which represents a significant advantage to your customers and is likely to mean that they have less incentive to switch to EU sourced materials. You will also get greater control over the REACH process and will not need to disclose proprietary information on the composition of your formulations to your customers, to allow them to make their submission under REACH.

Appointing an Only Representative has many advantages:

• A single point of contact for any REACH related issues
• The Only Representative works for you representing your interests
• Your EU importers and customers will favour companies who appoint an Only Representative as it removes the REACH obligation from them

If your importer registers your substance, it will be the importer, not you, that owns the registration. If they subsequently change to a new supplier, you will lose access to the EU market.

As your REACH Only Representative in the EU, JSC can:

• Help you to develop a REACH strategy which keeps registration costs to a minimum
• Undertake data gap analysis and data appraisals
• Prepare and submit your Technical Dossiers, Chemical Safety Reports, including exposure and risk assessments, and safety data sheets
• Represent you within the Substance Information Exchange Forum (SIEF) for your substance and if required set up and manage REACH consortia