Do I need a REACH Only Representative in Europe?

With the dead­line of June 1 2018 fast approach­ing, we are see­ing an increas­ing num­ber of for­eign sup­pli­ers con­tact­ing us about our REACH Only Rep­re­sen­ta­tion (REACH OR) ser­vice.

The first question we always get is, “Do I even need a REACH Only Representative?”

The answer as you may have guessed is always “It depends”. Although, To answer this ques­tion more com­plete­ly, we often turn the con­ver­sa­tion around. By ask­ing these for­eign sup­pli­ers the fol­low­ing ques­tions?

  • Are the prod­ucts you import into Europe con­sid­ered sub­stances under the REACH direc­tive?
  • What are the types of prod­ucts you import into Europe?
  • What quan­ti­ties of these prod­ucts do you import into Europe?
  • Do you have a sub­sidiary in Europe?

Are my products considered substances under the REACH directive?

Not all for­eign sup­pli­ers pro­duce “sub­stances” as defined in the REACH Euro­pean direc­tive. If a mate­r­i­al is not con­sid­ered a sub­stance, then there is no reg­is­tra­tion required under the REACH direc­tive. So, the first ques­tion to ask then is always: “Are the prod­ucts I am import­ing into Europe con­sid­ered a sub­stance under the REACH direc­tive?”

Are my products exempt from the REACH directive?

Many for­eign sup­pli­ers believe that their prod­ucts may not be con­sid­ered sub­stances or chem­i­cals. But, they prob­a­bly think that because they are not deal­ing in pure com­modi­ties. Or, that their prod­ucts are not raw mate­ri­als. Or even that their prod­ucts are exempt and there­fore they do not need a REACH OR.
More often than not, if they need to ask the ques­tion, then it is like­ly that their prod­ucts do indeed fall under the clas­si­fi­ca­tion of a sub­stance, and they do need a REACH Only Rep­re­sen­ta­tive.

There­fore, If you think about nail pol­ish, sil­i­cone, glue, epoxy and sur­face treat­ments, for­eign sup­pli­ers of these prod­ucts, all need to be have a REACH OR.

Most often, we get ques­tions from for­eign sup­pli­ers of phar­ma­ceu­ti­cals, agri­cul­ture (agro­chem­i­cal) and even spe­cial­i­ty chem­i­cals. And, all of which will require a REACH Only Rep­re­sen­ta­tive.

CAPLINQ is a spe­cial­ty chem­i­cals, plas­tics and prod­ucts com­pa­ny that spe­cial­izes in mak­ing for­eign com­pa­nies com­pete on a lev­el play­ing field with Euro­pean sup­pli­ers. Vis­it caplinq.com to learn more about our REACH ser­vices includ­ing our REACH Only Rep­re­sen­ta­tion. You can also con­tact us if you have fur­ther ques­tions about whether you need REACH Only Rep­re­sen­ta­tion.

About Chris Perabo

Chris is an energetic and enthusiastic engineer and entrepreneur. He is always interested in taking highly technical subjects and distilling these to their essence so that even the layman can understand. He loves to get into the technical details of an issue and then understand how it can be useful for specific customers and applications. Chris is currently the Director of Business Development at CAPLINQ.

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