REACH (Registration, Evaluation, Authorisation and Restriction of Chemicals) governs chemicals placed on the EU market. A frequent misunderstanding is that a non-EU manufacturer can be 'REACH registered'. In practice, a manufacturer based outside the EU cannot register directly — the obligation falls on the EU importer, or on an Only Representative (OR) the non-EU manufacturer appoints. Understanding where the responsibility sits is the key to a clean import. This article is general guidance, not legal advice.
Who carries the obligation
- EU importer of record: if you import a substance into the EU at or above one tonne per year, you are normally responsible for its REACH registration.
- Only Representative (OR): a non-EU manufacturer can appoint an EU-based OR to handle registration, which then covers its EU importers for the volumes the OR registers.
- Downstream users and distributors: rely on registrations upstream but still have duties around safe use and communication.
What a non-EU supplier should give you
- Clear substance identity (name, CAS/EC numbers) and composition data.
- A Safety Data Sheet (SDS) in the correct format, with the data needed for CLP-compliant labelling.
- An honest statement of registration status — whether a substance is covered by an OR registration, relies on your import registration, or is exempt.
- Support for your OR or your own registration with the technical information they require.
Questions worth asking before you buy
- Is this substance registered under REACH, and if so, through whom?
- Will you provide an SDS and the composition data for CLP labelling in my market?
- Can you support my Only Representative with substance information?
- Are there any restrictions or authorisation requirements (Annex XIV/XVII) on this substance?
Beware of overstated claims
Treat a blanket 'fully REACH registered' claim from a non-EU manufacturer with caution. The credible position is transparency: clear substance identity, a proper SDS, and an honest account of which registration route applies for each substance.
As a non-EU manufacturer, Ananta Industries supports your obligations as importer of record or via your Only Representative, providing substance identity, composition data, and a Safety Data Sheet, and we state per-substance scope plainly. Ask us about a specific product and we will tell you exactly what we can document.
