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Scope of REACH

How do I determine who is responsible for importing ?

You should register if you are the legal entity established in the EU who is responsible for importing.

The responsibility for importing depends on many factors such as:

  • Who orders?
  • Who pays?
  • Who is dealing with the customs formalities?
    However, this might not be conclusive on its own.

A sales agency established in the EU that acts as an intermediary, i.e. they transmit orders from buyers to non-EU suppliers (and are paid for this service). However, they take no responsibility for the goods or the payment of the goods and do not own the goods at any stage. In this case, the sales agency is not considered to be an importer for the purposes of REACH. The sales agency is not responsible for the physical introduction of the goods.

In many instances, this will be the ultimate receiver of the goods (the consignee) who is the legal entity responsible for importing the goods.

For further information and examples see chapter "Who is responsible for registration in case of import?" in the Guidance on registration:

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