Roles and Duties

What a company needs to do to comply with REACH will depend on their role and where they sit in the supply chain. The information provided here gives information about the different roles a company might have and what that means in terms of REACH responsibilities.

Under REACH, all ‘actors’ in the supply chain have a responsibility to ensure that they manufacture, place on the market or use substances without harming human health or the environment. The duties of an actor will depend on their role: be it a manufacturer, importer, downstream user or distributor. Non-EU companies can appoint only representatives to take on the duties of the EU importer, which is discussed below.

Manufacturer / Importer

A manufacturer under REACH is considered to be any company manufacturing a chemical substance within the EU, while an importer is any company that imports a chemical substance from outside the EU. These ‘actors’ are considered to be at the top of the supply chain and therefore have most of the responsibilities relating to the chemical that they introduce to the EU market. Their key task is to register any substance manufactured or imported at greater than 1 tonne per annum. Such substances can be substances on their own, in a mixture or incorporated into an article with the intention of being released from that article. Registration involves gathering information on the substances and submission of a registration dossier to the European Chemicals Agency (ECHA).

Registrants also have a responsibility to inform downstream users how to use substances safely and to communicate with users on any other aspects of REACH. Further information is available here and in our Chemical Importers Information Sheet.

If you are a new importer following the withdrawal of the UK from the EU, please see our additional supports below and visit our Brexit website.

• Guide for new importers of chemicals regulated by REACH
• Sample inventory

Only Representative (OR)

An Only Representative (OR) is an EU legal entity appointed by a non-EU manufacturer or formulator  to represent him in relation to REACH. The OR completes the registration dossier on behalf of all of the EU importers – who then become downstream users. Appointment of the OR must be made in writing by the non-EU manufacturer; the EU importers must have confirmation of this appointment and that their tonnage is covered by the arrangement. In addition to registration, the OR is responsible for all duties of importers in relation to all other aspects of REACH. To fulfil his duties, the OR must have the necessary experience, competence and resources to complete the tasks.

Further information is available here.

Downstream User

Companies that source their chemicals in the EU and use them in their industrial or professional activities are considered downstream users under REACH.. Downstream users have a key role to play in advancing the safe use of chemicals by implementing safe use at their own site and communicating relevant information both to their suppliers and their customers.

Further information is available here.

Distributor

A distributor is a person who stores and passes chemical substances onto third parties e.g. a retailer. The distributer has a duty to communicate information on substances within the supply chain, facilitating the movement of information from manufacturers on the safe use of chemicals and from downstream users on chemical uses.

Further information is available here and in our Distributors Information sheet.

Further Information

Our Chemicals Legislation Role Finder Tool is available to assist you in understanding your roles under the REACH, CLP, PIC and Detergents Regulations.