An Only Representative (OR) is a natural or legal person established in the EU, appointed by a non-EU manufacturer to carry out REACH registration for it. The role is set out in Article 8 of the REACH Regulation.
Once the OR registers a substance, the EU importers it covers become downstream users. They no longer need their own registration for that substance, within the tonnage the OR has covered.
Who can appoint an OR
Only a non-EU manufacturer of a substance, formulator of a mixture, or producer of an article can appoint an OR. A non-EU trader or distributor cannot. This is a common point of confusion with Indian sellers that do not run their own plant.
The manufacturer must also inform the EU importers in the same supply chain that it has appointed an OR. If you have not been told in writing, assume you are not covered.
What the OR must do
- Hold the REACH registration and meet all registrant duties, including updating the dossier when tonnage or hazard information changes.
- Keep up-to-date records of the quantities imported into the EU and the customers they were sold to.
- Keep the latest safety data sheet available and pass on information down the supply chain.
- Have enough knowledge of the substance and its regulatory obligations to act as registrant.
Why it suits many importers
For a small or mid-sized importer, an OR removes the need to buy data access, prepare a dossier and manage ECHA submissions. It also lets several importers share one registration, which is more efficient for the manufacturer. The trade-off is dependence: your legal cover rests on a contract between two other parties.
How it works in practice
Most ORs are specialist regulatory consultancies or law firms in the EU. The Indian manufacturer signs a contract with the OR, pays for the registration, and gives the OR a list of EU importers to cover with agreed annual tonnages.
Each year the OR collects import volumes from the importers it covers. If your volume grows past the band the OR registered, the registration may need an update before you import more. Plan this ahead of a large order.
OR cover is tied to one manufacturer. If you buy the same substance from two Indian plants, you need cover from both ORs, or your own registration for the second source. Read who is responsible for REACH registration for the trade-off between the routes.
How to check an OR claim
- Ask for a letter from the OR, not the supplier, confirming your company name, the substances and the tonnage covered.
- Check the registration in ECHA's public registered substances database by CAS or EC number.
- Confirm that the appointing company is the plant that makes your product, not a trading company.
- Ask what happens to your cover if the manufacturer ends its OR contract, and how much notice you would get.
Next step
We verify OR letters against the manufacturer we audited, so the paperwork matches the plant that ships your goods. See how it works, or book a free sourcing review.