About ORO

The Only Representative Organisation is the decisive voice of the EU Only Representatives (ORs) and the non-EU manufacturers as well as their value chains related to the REACH Regulation and its implementation.

ORO was founded in 2008, at the time when REACH started to be implemented with the REACH pre-registration phase. Since then, ORO has been a recognised stakeholder in the REACH debate by industry, regulators, NGOs and other industry associations. We have currently 35 Members in 10 different EU Member States.

About 25% of all REACH Registrations were conducted by Only Representatives, demonstrating the importance of Only Representatives for REACH. Only Representatives support non-EU manufacturers and their value EU chains, providing them access to the EU market. Thanks to our industry association non-EU manufacturers were not discriminated under REACH and ORO contributed to the goals of REACH significantly. ORO is dedicated to the following objectives:

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Set up Quality Standards for Only Representatives

Agreement on minimum requirements and basic standards that an ORO member must fulfil
Promote these standards towards stakeholders
Increase the reputation and importance of our industry segment

Common Understanding of REACH

Develop a mutual understanding of REACH requirements for ORs and non-EU manufacturers and their value chains
Launch working groups and committees to address specific areas of concern to the Membership
Establish a communication network between members on technical and regulatory issues related to REACH Implementation

Interests Representation

Represent the interests of ORs and non-EU manufacturers
Cooperate with regulators and other stakeholder in the REACH process
Promote ORO members as superior sources for OR Services

What is an Only Representative?

According to the European REACH regulation¹ and its counterparts KKDIK² in Turkey, UK REACH³ in Great Britain and K-REACH⁴ in Korea, importers are subject to the obligation to register all imported chemical substances, unless substances are exempted from this obligation.

To enable importers to be exempted from these registration obligations, the respective regulations provide that non-domestic manufacturers and formulators can appoint a so-called Only Representative (OR), who registers the respective substances on behalf of the manufacturer/formulator and thus makes the respective importers so-called Downstream Users (DU).

For this purpose, the OR must keep records of the respective importers as well as their annual imported substance quantities.

In the EU REACH regulation, REACH Art. 8 provides the legal framework for the important role of an Only Representatives in the regulation. Since this is the only Article of the 141 Articles in the REACH Regulation, addressing the roles and obligations of ORs, this leaves plenty of room for many misunderstandings and misinterpretation on obligations of Only Representatives.

The role of an Only Representative is extremely important, in particular for non-EU manufacturers wanting to access the EU market. Given the complexity of the REACH Regulation and the fact that there is no one-stop shop that can provide high quality information on Only Representative issues, many non-EU companies and their EU customers are very concerned. Therefore, ORO provides this missing link.

[1] Regulation (EC) No 1907/2006 of the European Parliament and of the Council of 18 December 2006 concerning the Registration, Evaluation, Authorization and Restriction of Chemicals (REACH).

[2] Turkish Regulation on Registration, Evaluation, Authorisation and Restriction of Chemicals, 23 June 2017.

[3] UK Registration, Evaluation, Authorisation & Restriction of Chemicals (REACH).

[4] K-REACH: Act on Registration, Evaluation, etc. of Chemicals (Act No. 17326).