If you export to Europe, the first thing you need to be conscious about is that the pre-registration window opened in 2007 and was open until 2008 and the registration window that is open until 31stMay 2018, is based on the tonnage a substance is imported or manufactured in the European Union. REACH (Registration Evaluation Authorization and Restriction of Chemical) regulation is for the European Entity, but for those out of EU or EEA have an option to comply with the mandatory regulation by appointing an Only Representative (OR, an EU entity) or with the help of a Third Party Representative (TPR). We all need to understand that for doing business with European countries beyond 31st May 2018, our position stands as “No Data No Market”.
With regards to OR term in the legal text of EU REACH, the primary aim was to address the situation where a non-EU manufacturers do not wish to divulge "sensitive information to an importer with whom he might not have a relation of complete trust." The secondary aim was to ensure that a non-EU manufacturer who markets his goods in the Community by means of a multiplicity of importers need only file a single registration with respect to a given substance.
“An only representative appointed after 1 December 2008 can pre-register the substance until 12 months before the relevant registration deadline (last deadline to late pre-register is 31.05.17), provided that the substance originating from the non-EU manufacturer was not placed on the market previously in a quantity at or above one tonne per year after 1 June 2008 (when the registration obligations entered into force)”
Trust House Solutions truly understands the European REACH regulations and can support exporters to comply with the REACH regulations through its European Partner; who are more than willing to support the non-EEA countries and take up responsibility of an OR. Trust House Solutions also extends technical support by playing the role responsible of TPR for the valued customers.
We provide all services, as required under REACH compliance that also includes preparing a valid Safety Data Sheet (SDS) & label, participating in Substance Information Exchange Forum (SIEF), working and communicating with REACH-IT, Communicating with Downstream Users (DU) to collect information towards end-use application of substance, interacting with the Lead Registrant (LR) and obtaining the Letter of Access (LOA), preparing technical dossier using IUCLID 6 for ELINCS and EINECS substances as defined under REACh regulation EC 1907/2006.
We have not restricted ourselves, for we are also more than willing to support customers who are open for an OR change or require technical assistance while still continuing with their current OR for various reasons.
We always say
“One step taken to meet compliances is equivalent to two positive steps taken towards protecting life”.