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Do I need to register?

You need to determine whether it is you who needs to register a substance or another actor in your supply chain. 

 

1. What is your identity as a registrant?

You can only register if you are a natural person or represent a legal person, as defined by your national laws. If your company has established several legal persons, for example, daughter companies or subsidiaries, each of those legal persons will need to submit their own registration.

 

2. Where are you located?

You can only register if you are located in the European Economic Area (EEA). This includes Austria, Belgium, Bulgaria, Croatia, Cyprus, the Czech Republic, Denmark, Estonia, Finland, France, Germany, Greece, Hungary, Iceland, Ireland, Italy, Latvia, Liechtenstein, Lithuania, Luxembourg, Malta, the Netherlands, Norway, Poland, Portugal, Romania, Slovakia, Slovenia, Spain, Sweden, and the United Kingdom.

If you are located outside the EEA, you will need either an importer or an ‘only representative' to register you substance.

 

3. What is your role in the supply chain?

The various roles have specific definitions under REACH, which do not always correspond with those used elsewhere.

You can have multiple roles for a substance - consider all of them.

You need to register if you:

  • manufacture a substance: you produce a substance or you extract it. 
  • are responsible for the import into the EEA of a substance: you are responsible for the physical introduction into the territory of the EEA of the substance (on its own, in a mixture or in an article). However, you do not have to register if:
    • All your suppliers have appointed only representatives; or 
    • You re-import a registered substance; or 
    • Your substance is under customs supervision, with a view to re-exportation. 
  • produce or import an article: you incorporate a substance or mixture into or onto a material to form an article, or are responsible for the import into the EEA of such an article. However, you do not have to register if:
    • the substance is not intended to be released; or 
    • the substance has been registered for the same use by any company. 
  • have been appointed as an only representative: your suppliers outside the EEA (manufacturers or producers of an article or mixture) have appointed you to fulfil the obligations under REACH that would otherwise lie with their importers. 

 

You do not need to register if you only:

  • distribute a substance: you store and place substances on the market, on their own or in mixtures, for third parties. 
  • refill: you transfer substances or mixtures from one container to another, generally in the course of repackaging or rebranding. 
  • formulate: you produce mixtures (e.g. paints, adhesives, detergents, diagnostic kits), which are usually supplied further downstream. 
  • are an end-user: you use chemical products but do not supply them further downstream.

Do I need to register?


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