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Actors in the EU REACH regulation

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REACH regulatory obligations only apply if your company meets the regulation’s definition of an importer, manufacturer, downstream user or distributor.

Importer

You import substances, mixtures or articles into the EU.

means any natural or legal person established within the Community who is responsible for import;

Regulation (EC) No 1907/2006, Article 3(11)

Manufacturer

You manufacture or synthesize substances or mixtures in the EU.

means any natural or legal person established within the Community who manufactures a substance within the Community

Regulation (EC) No 1907/2006, Article 3(9)

Downstream User

You source substances or mixtures from other EU companies and use them in the EU.

means any natural or legal person established within the Community, other than the manufacturer or the importer, who uses a substance, either on its own or in a mixture, in the course of his industrial or professional activities. A distributor or a consumer is not a downstream user.

Regulation (EC) No 1907/2006, Article 3(13)

Distributor

You facilitate the distribution of substances, mixtures and articles in the EU but you do not import, manufacture or use.

means any natural or legal person established within the Community, including a retailer, who only stores and places on the market a substance, on its own or in a mixture, for third parties;

Regulation (EC) No 1907/2006, Article 3(14)

Other actors

Some companies holder other roles in the REACH regulation, but are not in themselves duty holders, unless they have customers in the EU Market or are appointed as an Only Representative

Non-EU Manufacturers or Formulators

You manufacture or blend substances or mixtures to make formulations outside of the EU.

Only Representative

You are an EU entity that has been appointed by a non-EU manufacture or formulator to undertake certain REACH obligation on their behalf.


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Steven Brennan

Steven is a Regulatory Consultant and helps companies to maintain compliance with chemical regulations. He writes about REACH, RoHS and other environmental regulations in his spare time.

1 thought on “Actors in the EU REACH regulation”

  1. Pingback: The Ultimate Guide to REACH Compliance | REACH Compliance

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