For non-European companies that sell into Europe the REACH regulations can pose a difficult and complex set of laws in another part of the globe which can still have an effect indirectly on your business. The nature of the regulation and punitive measures attached mean that only businesses within Europe face penalties for failing to remain compliant. However for overseas sales this means the first importers or your clients in Europe must meet the full requirements of registration unless an Only Representative is in place.
The use of an ‘Only Representative’ allows non-European companies to appoint a spokesperson, who must be based within Europe, to take on the obligations of REACH on their behalf. This allows Non-European companies the chance to be involved in the regulation and have a voice. It also converts all importers within Europe to what are called ‘Downstream users’, lifting the burden of registration from your clients and maintaining a level playing field with manufacturers who are based within Europe.
The NCEC Only Representative services has been in operation since the creation of the regulation and witnessed first-hand the process and kind of issues that can arise during the first two registration deadlines for larger tonnages (>1000 t 2010 and 100-1000 t 2013). While the next registration deadline is not until 2018, it will focus on the smaller tonnage brackets more likely represented by Small-Medium sized Enterprises (SMEs). As part of the NCEC’s duty of good care we strongly recommend all clients and potential clients to plan for registration and not leave everything until 2018. The costs for data packets (letters of access), ECHA admin fees and understanding the supply chain can take time and money, so multiple registrations in the same year can add up!
It is also important to recognise the obligations of the REACH regulation continue post-registration with items such as the evaluation programme, or addition to the candidate list for substances of very high concern post registration. The NCEC Only Representative services are well placed to help you get to grips with the current demands of the REACH regulation and plan for your businesses future within the European REACH regime. We also offer a joined up and integrated set of services to help you manage from where REACH ends and CLP begins.
For further information on the NCEC Only Representative services or to discuss how we can help you please contact us and we shall be in touch shortly.