REACH regulatory obligations only apply if your company meets the regulation’s definition of an importer, manufacturer, downstream user or distributor.
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)
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 CommunityRegulation (EC) No 1907/2006, Article 3(9)
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)
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)
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.
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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