Regulatory Compliance

REACH – ‘Only Representative' and 'Third Party Representative' services

The Registration, Evaluation, Authorisation and restriction of Chemicals (REACH) regulation places obligations on manufacturers and importers within the EU to carry out the specific tasks outlined in the regulations, namely the pre-registration/registration of dossiers for chemical substances manufactured or used at more than 1 tonne per year. To help maintain a commercial ‘level playing field’, it is possible for non-EU companies to appoint an 'Only Representative' who is based in the EU and takes on the obligations of the importer, essentially converting them to a downstream user.

This is a useful way for non-EU companies to maintain a presence in Europe, where, for example, clients may have the choice of buying their goods from an EU company (which would need to complete the REACH registration) or from a non-EU company where the obligation would then fall onto the client.

It is also possible for EU manufacturers to appoint a 'third party representative' who takes part in the Substance Information Exchange Forum (SIEF) negotiation on behalf of a given client. This allows the client to remain anonymous during the SIEF negotiations. Because the REACH registration process brings together all the companies registering the same substance, and encourages sharing of knowledge and data, it can sometimes be useful to remain anonymous, particularly when sharing data that could be seen as commercially sensitive (e.g. production rates).

Over the last four decades, NCEC has developed an in-depth knowledge of the global chemical marketplace and its critical interactions with stakeholders – from regulator to supply chain. This means we are ideally placed to act as your Only Representative or Third Party Representative. Why divert resources and disrupt day-to-day operations?  Let us take care of the REACH registration process for you substances?

Only Representative

We work closely with the European chemicals industry and have a full understanding of chemical manufacture and distribution. This expert knowledge means that we are ideally placed to act as 'only representative' for non-EU companies.

As part of NCEC’s 'Only Representative' service, a dedicated member of staff is appointed to help clients manage the demands of the REACH registration process. Specific details of the service include:

  • Establishing a REACH-IT account so you can communicate with the European Chemicals Agency (ECHA).
  • Helping with late pre-registration for new substances to market.
  • Communicating on your behalf during SIEF negotiations in compiling data for registration.
  • A team, which is fully conversant with the International Uniform Chemical Information Database (IUCLID), to help complete the dossier part of registration. 
  • Experts to help answer enquiries and questions you may have as the REACH process continues.
  • Providing a valid and bona-fide port of call for all downstream users to give them peace of mind that the REACH obligations are in hand.
  • Further expertise should you need assistance in developing a chemical safety report (CSR) or exposure scenarios (ES) for extended safety data sheet (ESDS) authoring.

Third Party Representative

As a Third Party Representative, NCEC is able to play a full part in the SIEF negotiations required to fulfil the registration dossiers under REACH. This careful management of the data and client engagement allows companies to take part in negotiations and have a full say in the outcomes while protecting their identity. In competitive markets this kind of engagement can prove extremely valuable.

The NCEC Third Party Representative services include:

  • Establishing a REACH-IT account so you can communicate with the ECHA.
  • Helping with late pre-registration for new substances to market.
  • Communicating on your behalf during SIEF negotiations in compiling data for registration, which will be done using NCEC letterhead to protect the identity of the company seeking compliance.
  • A team, which is fully conversant with the International Uniform Chemical Information Database (IUCLID), to help complete the dossier part of registration. 
  • Experts to help answer enquiries and questions you may have as the REACH process continues.
  • Providing a valid and bona-fide port of call for all downstream users to give them peace of mind that the REACH obligations are in hand.
  • Further expertise should you need assistance in developing a CSR or ES for ESDS authoring.