Guidance on registration - ECHA - Europa

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24 <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. Annankatu 18, P.O. Box 400, FI-00121 Helsinki, Finland | Tel. +358 9 686180 | Fax +358 9 68618210 | echa.europa.eu
<strong>Guidance</strong> on registration Version 2.0 May 2012 25 However, industry associations can provide very valuable assistance to registrants for the preparation of registration dossiers, and can help in co-ordinating the process. In addition they may have valuable data on the substance that can be used in the data sharing process. They could also be appointed to represent a registrant in discussions with other registrants regarding preparation of the joint submission of hazard data and act as third party representative. They can include non-EU enterprises as members, who, even though having no direct registration obligations, can provide information and assistance through these associations. Annankatu 18, P.O. Box 400, FI-00121 Helsinki, Finland | Tel. +358 9 686180 | Fax +358 9 68618210 | echa.europa.eu
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Guidance on registration - ECHA - Europa

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