• English
  • USD
  • Select metric or imperial units

    Choose to display your values in imperial or metric units

  • Cart empty,
    View Cart
    Shopping cart overview
    Your Cart is currently empty.
  • x

REACH OR Representation Service

REACH Only Representatives keep their clients REACH compliant

Appoint CAPLINQ as your REACH OR
{javascript-bookmarks}

What is a European REACH Only Representative?

In a nutshell, a REACH Only Representative provides a legal entity in the European Union (EU) for the "chemical import responsibility" of substances into Europe.

On June 1st, 2007, the European REACH Regulation (EC1907/2006) came into force in the European Union. In short, the goal of REACH is to have a clear picture of the types and quantities of chemical substances that are manufactured or imported into the European Union. REACH regulation compliance requires all companies manufacturing or importing chemical substances in the EU to register these substances with the European Chemicals Agency (ECHA).

Only companies that have a legal presence within the European Union (EU) can be REACH Only Representatives and can submit REACH registrations dossiers to ECHA. Non-EU companies must appoint a representative to be the REACH Only Representative.

REACH Only Representatives are the "chemical importer of record"

REACH Only Representation is like Fiscal Representation but for chemical substances. A European fiscal representative provides a "fiscal import responsibility" for goods into Europe. This means that they are the "fiscal importer of record", responsible for the custom clearance, duty payment and other fiscal administrative responsibilities.

Similarly, REACH Only Representatives relieve the foreign entity of the responsibility of chemical reporting to ECHA. As such, they assume the "chemical import responsibility" for chemical substances into Europe and become the "chemical importer of record".

A REACH OR provides a legal entity in the European Union for suppliers to have their chemical substances subjected to either a REACH Pre-registration or REACH Registration process.

What does a REACH Only Representative do?

A REACH Only Representative assumes the risk and responsibility of foreign suppliers importing chemical substances into Europe.

Essentially, the function of a REACH OR is to make sure that foreign suppliers importing chemical substances into Europe comply with ECHA REACH regulations. This includes collecting data and information, monitoring chemical substance type and quantity, issuing REACH Certificates and updating foreign suppliers on REACH regulation changes.

Collecting data on chemical substances to submit to ECHA

The first task of a REACH OR is to collect data on the types and quantities of chemical substances being imported into Europe. In this stage, it is assessed whether a product requires a REACH Pre-Registration or REACH Registration with ECHA.

REACH OR monitors types & quanties of chemical substances

If after investigation, it appears that the type and quantity of chemical substance imported into Europe requires a REACH Pre-Registration (or Registration), the REACH OR puts together the dossier required to be submitted to ECHA.

REACH Certificates and monitoring regulatory changes

The quantities and types of substances change over time, as do the regulations surrounding them. REACH Only Representatives monitor this situation constantly. They issue REACH Certificates to signal that foreign suppliers are still complying update them on regulatory changes.

Do I even NEED a REACH Only Representative?

If the following apply to you, then you will likely need a REACH Only Representative to continue importing your goods into Europe beyond 2018

You are a chemical substance manufacturer

You supply products defined as "chemical substances" into Europe

You are a foreign supplier

You are a foreign manufacturer manufacturing chemical substances outside of Europe

You are a chemical substance distributor

You import chemicals from outside Europe into Europe

Who needs REACH Only Representation?

Any foreign manufacturer supplying chemical substances into Europe needs REACH Only Representation if he plans to supply these chemicals beyond June 1, 2018.

A substance is defined in REACH by Article 3 and in CLP by Article 2 as: “a chemical element and its compounds in the natural state or obtained by any manufacturing process, including any additive necessary to preserve its stability and any impurity deriving from the process used, but excluding any solvent which may be separated without affecting the stability of the substance or changing its composition”.

Foreign companies exporting to Europe need a REACH Only Representative

Only companies that have a legal presence within the European Union (EU) can be REACH Only Representatives and can submit REACH registrations dossiers to ECHA. Non-EU companies must appoint a representative to be the REACH Only Representative.

Chemical Substance Distributors

Even if you are not the manufacturer of the chemical substance, but only the distributor of a manufacturer's product, it is your responsibility to have a REACH Only Representative if you import this product into the European Union. It is the responsibility of the importer of record to be sure there is REACH Only Representative of the chemical substance being imported.

Why should I appoint CAPLINQ as my REACH Only Representative?

CAPLINQ is more than just a REACH OR. We are a market partner that opens the European market to foreign suppliers

We are a business. We understand you.

We hate bureaucracy as much as you do. We won't waste your time - or your money.

Trusted Member of ORO

ORO Members are REACH experts that have their fingers on the pulse of REACH regulations.

A market partner you can trust

With other business systems in place, we open the European market to foreign suppliers.

Why should you appoint CAPLINQ as your REACH Only Representative?

CAPLINQ's core competency is specialty chemicals and plastics. Our practical approach to REACH Only Representation focuses on the most cost effective method of keeping foreign suppliers REACH compliant.

Your data is sensitive, we sign NDA's. You just want to be sure you are REACH compliant and have it all taken care of, we get that and do that. You want reports to be sure everything's documented. Check. You want all this, and it can't cost a fortune. It won't. CAPLINQ is a member of ORO and understands what our customers expect in a REACH Only Representative, wouldn't you also like that peace of mind?

CAPLINQ is an experienced REACH Only Representative

Since 2004, CAPLINQ has worked with manufacturers and producers in the United States, Canada, China, Korea, Africa, Taiwan, Japan, Russia, Turkey, Morocco, and Singapore. We have worked with all these companies to physically bring their products to market in Europe. This means that we have been involved in the export of the goods from the country of origin right to the customer's door in Europe.

The handling of chemical substances has always been CAPLINQ's core competency. Once REACH was introduced in 2007, it was then a natural evolution that our suppliers asked us to become their REACH Only Representative. Our main customers today for REACH Only Representation are specialty chemical companies that manufacture everything from epoxies to nail polishes to specialty chemicals and import these chemical substances into Europe.

CAPLINQ provides free, unlimited access to our REACH experts

To find out what other services are included in CAPLINQ's REACH Only Representative service or click here to find learn about all the REACH Services CAPLINQ provides. Follow this link to see what a REACH Only Representative Contract looks like.

Frequently Asked Questions

What is the definition of a chemical "substance" in REACH?

Article 3 in REACH defines a substance as: “a chemical element and its compounds in the natural state or obtained by any manufacturing process, including any additive necessary to preserve its stability and any impurity deriving from the process used, but excluding any solvent which may be separated without affecting the stability of the substance or changing its composition”

Why doesn't CAPLINQ charge an hourly consulting fee when everyone else does?

Once we know how many substances are concerned, we know immediately how much work is involved. Based on this information, we can offer a price that covers all the work involved. An hourly consultation fee might make people hesitate to ask the questions that need to be asked, and we do not believe this to be the proper REACH Only Representative relationship.

What other fees can I expect from CAPLINQ as REACH Only Representative?

Our annual REACH Only Representative fee covers all pre-registration, record keeping, communications with the authorities and your customers and, within reason, answering all the questions that you or your customers may have. Unless we specifically agree on additional services, you will not get additional invoices.

What is included in CAPLINQ's REACH OR Services?

  • Free, unlimited access to our REACH experts for advice
  • Create legal presence in the European Union (EU) for the REACH Registration process
  • Collect data required on the chemical substances to submit for REACH (pre)registration
  • Monitor quantities of substances imported into EU
  • Advises if threshold of substance quantities are being approached
  • Issue yearly chemical substance import reports
  • Issue REACH Certificates to your customers in the European Union
  • Updates on REACH legislative changes and updates

What determines the cost of CAPLINQ's REACH Only Representative Service?

We offer a single price depending on the number of chemical substances to be (pre-)registered. Our price breaks are for as follows: 1 substance, 2-4 substances, 5-10 substances, 11-20 substances, 20-50 substances and 50+ substances. Contact us for a detailed REACH Only Representation proposal.

Are there any other costs involved?

CAPLINQ has no other costs involved. Depending on the nature and quantities of the chemical substances involved, you may have to have some substances go through REACH Registration, and if this is the case there are some ECHA costs involved. REACH Pre-registration and REACH Registration are topics that require their own pages, and they are discussed separately.

What does REACH mean by a "downstream user"?

REACH defines "downstream users" as companies or individuals who use chemical substances, either on its own or in a mixture, in the course of their industrial or professional activities. If you are an importer or a distributor, it roughly means that these are your customers. Once a substance is imported by the Only Representative into the EU, it is the downstream users who will use the products.

So what does a REACH Only Representative Service Agreement Look like?

Please see the example of a draft REACH OR Contract