According to the REACH Regulation, companies of the non-EU countries do not have direct obligations under the REACH Regulation. However, it is the importer who needs to comply with the REACH obligations. According to the Article 3(11) of the REACH Regulation, importer means any natural or legal person established within the Community who is responsible for import. On the other hand, according to Article 3 (9) of the REACH Regulation, a manufacturer means any natural or legal person established within the Community who manufactures a substance within the Community.
Non-EU companies exporting chemical substances on their own are not obligated to appoint an “only representative” according to the Article 8 of the REACH Regulation to fulfill the obligations of importers. However as a non-EU company such industries still need to take the REACH Regulation into observation. Why? Although you may be established in a non-EU country, you have to take into observation that some of your business partners might be based in the European Union. Even though, placing REACH Regulation into action it might be out of your direct line of sight, but you still have to pay attention to the details of the REACH Regulation. If not, someone downstream in your industry sales chain will be affected which will have a major impact on your industry as well.
For further information on REACH compliance, You may visit http://www.nexreg.com/
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