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Only Representative of non-EU manufacturer
What are the obligations of polymer importers (or ORs appointed by non-EU polymer manufacturers), if an OR has already been appointed by the non-EU monomer producer up the non-EU supply chain, but this OR does not want to take on the legal responsibility envisaged in Article 8 of REACH for the polymer importers?
In the case of polymer imports, the condition "have already been registered up the supply chain" in Article 6(3) REACH can only be fulfilled if an OR appointed up the non-EU supply chain (e.g. the OR of the non-EU monomer manufacturer) has decided to also cover the polymer imports with their registration (i.e. included the volumes concerned in their registration and took over the obligations in Article 8(2) and 8(3) of REACH). If the OR of the non-EU monomer manufacturer decides not to take legal responsibility for these volumes, the polymer importer cannot rely on the exemption from registration and is obliged to register the volumes of monomer they import. Alternatively, an OR appointed by the non-EU polymer manufacturer could register on behalf of the polymer importers.
Modified Date: 04/06/2015
This answer has been agreed with national helpdesks.