Why your REACH OR needs Only Representative Organization (ORO) Membership

What is REACH ORO Representative Organisation (ORO) Membership?

Only Representative Organisation (ORO) is dedicated to discuss and give guidance on all issues concerning Art. 8, in the Regulation (EC) 1907/2006 (REACH)

REACH and specifically Only Representation (OR) are still in their formation years. Though REACH came into effect on June 1st of 2007, the first deadline came into effect on December 1st, 2010 and the third deadline is not until June 1st of 2018.

These long lead times are intentional since REACH and Only Representation are new for everyone, from the people it is meant to protect, to the suppliers who need to abide by the new regulations to even the lawmakers and enforcers of the legislations.

Who are ORO members and what do they do?

A lot of the rules have changed since 2007 and a lot more will change before 2018. The lead authority on the matter is the European Chemicals Agency (ECHA). The ECHA is the driving force behind REACH and they continue to generate REACH Manuals and Publications that companies can use to facilitate the implementation of REACH.

Of course, there needs to be a counter weight to this European Authority, a group that can propose alternatives, lobby policy and otherwise act to group Only Representatives together to make sure that the decisions and policies made by ECHA are in the best interest of everyone involved - this group is the Only Representative Organisation.

REACH Only Representation is as yet an unregulated industry. As such, it is still not required to be an ORO member to be an Only Representative. However, it is definitely advisable that your REACH Only Representative be a member of ORO. Keep reading to learn why.

Can anyone be a REACH ORO Member?

No. In fact, it's quite difficult to become one. Once the REACH Only Representative's application is submitted, it is reviewed by a committee for approval. A background check is done on the European company and then the name is shared with all ORO members. Each member has the right to offer an objection to the new member's application. Only if there are no objections, does the ORO Membership application process continue.

Is your REACH Only Representative an ORO member?

ORO Members are insured for REACH Only Representation

ORO Members have a "REACH Only Representative insurance" that protect foreign suppliers of chemical substances

REACH Only Representatives acts as the "chemical importer of record" for foreign manufacturers. This means they remove the risk from these foreign suppliers and take it on themselves. If mistakes or errors occur, the REACH Only Representative is the one responsible, and risks heavy fines. Fortunately, as a member of ORO, REACH OR's are able to benefit from a special insurance which protects both the REACH OR and the foreign manufacturer from these fines.

Beware of REACH OR's without insurance!

The internet is full of shady offers to offer "Low Cost REACH OR" or "£99/year REACH Only Representative Services". Be sure to check if your REACH OR is a member of ORO - then you will know that he is insured and that you are not at risk of misrepresentation.

Is your REACH Only Representative an ORO Member?