Guidance on registration - ECHA - Europa

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<strong>Guidance</strong> on registration
Version 2.0 May 2012
Example: Role and registration obligations of different actors when an only
representative is appointed
OUTSIDE EU
EU
Non-EU
Manufacturer 1
3 tonnes
Role and Registration
obligations
Non-EU
Manufacturer 2
5 tonnes
Importer 1
Importer 1
- registers 3 tonnes
- is regarded as a downstream user
for the remaining 5 tonnes
Appoint as Only Representative
Appoint as Only Representative
Only representative
Only representative
- registers the tonnage exported by
the non-EU manufacturers 2 and 3
separately, i.e. he registers 8 tonnes
for non-EU manufacturer 2 and 8
tonnes for non-EU manufacturer 3.
Non-EU
Manufacturer 3
3 tonnes
5 tonnes
Importer 2
Importer 2
- does not need to register
- is regarded as a downstream user
3 tonnes
Non-EU distributor
3 tonnes
Importer 3
Importer 3
- does not need to register
- is regarded as a downstream user
Import of mixtures when an only representative is appointed
An importer of mixtures is obliged to register the individual substances in the mixtures he
imports and needs to know therefore the chemical identity and the concentration of the
substances in the mixtures. If the ‘non-EU manufacturer’ of the mixture or of the individual
substances in the mixture appoints an only representative, it will be the only representative
who will carry out the registration of the individual substances instead of the importers. The
‘non-EU manufacturer’ will inform the importers that an only representative has been
appointed. If the ‘non-EU manufacturer’ appoints separate only representatives for the
different substances in the mixture or only appoints only representatives for some of the
substances in the mixture, this information needs to be communicated clearly to the importers,
so that they are aware of which obligations they are relieved of and which obligations they still
have to fulfil pertaining the registration of the susbtances. In any case, the importers of the
mixtures and the corresponding only representative(s) must be able to document which
quantities of the substances imported in the mixture(s) are covered by the registration dossier
of the only representative(s) and which quantities are covered by the registration dossier of
the importers themselves.
2.1.2.6 Role of industry associations and other types of service providers
The actual registration of a substance can only be done by the manufacturer, importer or
producer of an article or only representative and cannot be done by any third party including
industry associations, unless they act as the only representative for one or more non-EU
companies.
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