Position Paper 2014
Position Paper
Only Representatives and late Pre-registrations
Introduction
The issue
Non-European manufacturers and formulators regularly appoint Only Representatives to take over REACH obligations from their European customers, the importers, at a time where their products are already on the EU market. They generally perform these ‘late OR appointments’ for commercial reasons; to reduce the administrative burden of their customers, to support their EU/EEA customers so they should not have to submit registrations themselves, to ensure
the confidentiality of their formulations, to give REACH compliance of their products in more competent hands, and most importantly, to service new customers and new markets, or those customers who only wish to do business if an Only Representative is involved.
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