Ingredients, raw materials and B2B chemicals

• Regulation (EC) No 1907/2006 — REACH
• Regulation (EC) No 1272/2008 — CLP
• Regulation (EC) No 1333/2008 for food additives
• Regulation (EC) No 1223/2009 Annexes for cosmetic ingredients

Who has to appoint one

Manufacturers outside the Union supplying substances or mixtures to EU customers. An only representative can be appointed to take on the registration obligations that would otherwise fall on each EU importer, which is commercially valuable but carries the full registrant liability.

Thresholds and exemptions

REACH registration from one tonne per year per legal entity. CLP labelling and poison centre notification apply regardless of tonnage for classified mixtures. Food additives and cosmetic ingredients follow their own authorisation lists.

What must appear on the label

CLP labelling with pictograms, signal word and statements, the supplier's EU details, and for mixtures the UFI. Food additives carry the E number and the required designations; cosmetic ingredients must comply with the Annex restrictions.

Marketplace fields

EU customers require the registration number, the safety data sheet in their language and the extended exposure scenarios where applicable, and will not purchase without them.

Documentation you must hold

REACH registration dossier and chemical safety report above ten tonnes, safety data sheets per language with exposure scenarios, only representative appointment documentation with the list of covered importers, and authorisation or restriction compliance evidence.

Standards and testing

Physicochemical, toxicological and ecotoxicological testing per the tonnage band, with data sharing obligations through the substance information exchange forum.

Language requirements

Safety data sheets in the official language of every member state where the substance is placed on the market.

When it applies

Registration before import. There is no grace period once the tonnage threshold is crossed, and importers cannot buy lawfully until it exists.

How long records are kept

Ten years after the last manufacture, import or supply.

What happens if you do not comply

Import blocked at customs, enforcement orders, and fines. The only representative carries registrant liability, which is why the role is taken by specialist firms rather than general service providers.

Who enforces it

ECHA and national enforcement authorities, food safety authorities for additives, and cosmetics authorities for ingredient restrictions.

Where the boundary lies

An only representative under REACH is a substantively different role from a GPSR responsible person or an Article 27 GDPR representative: it assumes technical and financial obligations for registration, not a contact function, and requires chemical expertise.

Questions we are asked

Can our EU customer register instead?

Yes, each importer can register its own volumes, which is why some suppliers avoid the only representative route. The trade-off is that your customers see each other's volumes and bear the cost.

Does an only representative cover all our customers?

It covers the volumes it registers for the importers it lists, and those importers are then treated as downstream users. The list must be kept current.