Under EU REACH, the importer is responsible for registration. An Indian supplier cannot register directly, because only a legal entity established in the EU can submit a dossier to ECHA.
There is one way to shift the duty. The non-EU manufacturer can appoint an Only Representative (OR) in the EU, who registers on its behalf. Importers covered by that OR are then treated as downstream users, not registrants.
The two routes compared
- Importer registration: you join the registration for each substance, usually by buying a letter of access to the joint dossier. The registration belongs to your company and covers only what you import.
- Only Representative registration: the manufacturer's OR holds the registration. It can cover several EU importers buying from the same plant, each within an agreed tonnage.
- Mixed cases: some substances in a product may be covered by an OR and others not. You then register the uncovered ones yourself or find another source.
Which route suits you
Importer registration gives you control. The registration stays with you if you change supplier, which matters if you plan to buy the same substance from several Indian plants. The cost of data access and fees falls on you, and the work is real.
An OR route is lighter for you, but it ties you to that manufacturer. If you switch to another plant, the new plant needs its own OR registration, or you need your own. Ask whether the OR covers your tonnage and your use, and get that in writing.
A trading company in India cannot appoint an OR. Under ECHA guidance, only a non-EU manufacturer, formulator or article producer can. If a seller offers OR cover, check that it is the actual manufacturer. Our guide to telling a chemical trader from a manufacturer explains the checks.
What you must keep on file
Whichever route you use, keep evidence that each import was covered. Inspectors ask for it, and it is your defence if a shipment is questioned.
- The REACH registration number for each substance, or the OR's confirmation that names your company.
- Your annual import tonnage per substance, so you can show you stayed within the band covered.
- A current SDS in the correct format and language for your market.
- Any correspondence where the supplier confirms composition, because a change in recipe can take a substance out of cover.
Common mistakes
The most common mistake is accepting a registration number without checking it. A number may belong to a different legal entity, a different substance or a lower tonnage band. Check it against ECHA's database and ask the OR to confirm your company is on its list.
The second is forgetting that registration follows the legal entity. If your group imports through two EU companies, each needs cover. For legal certainty, confirm your position with your national REACH helpdesk or a regulatory adviser. The wider rules are set out in what EU REACH requires.
Next step
We collect and check REACH evidence as part of supplier vetting, so you know which route you are on before you order. To start, book a free sourcing review.