REACH
REACH Only Representative: Requirements, Cost and the Three Roles People Confuse
"Only Representative" gets mixed up with two other EU-appointed roles constantly, and the confusion isn't accidental — all three exist to solve a version of the same problem (a non-EU business needs an EU-based accountable party) but under three separate regulations, with three separate legal effects.
What an OR Actually Does
- Registers substances with ECHA on behalf of a non-EU manufacturer
- Holds records of the EU importers in that supply chain and their import volumes
- Manages safety data sheets for downstream users
- Reclassifies EU importers as downstream users once appointed, shifting registration duty off them
Quick answer: A REACH Only Representative (OR) is an EU or EEA-established party a non-EU manufacturer can appoint, under Article 8 of Regulation (EC) No 1907/2006, to take on the manufacturer's REACH registration duties for a given substance — freeing the EU importers in that supply chain from having to register it themselves. It's a REACH-specific role, distinct from the Authorised Representative used under CE-marking legislation and the Responsible Person required under GPSR, even though all three get shortened to similar-sounding acronyms and regularly get confused.
Why Three EU Roles Exist for One Problem
Same Underlying Need, Three Separate Legal Answers
The reason OR, AR and RP keep getting confused isn't carelessness — the three roles genuinely address a version of the same underlying problem from three different EU product regulations that were written at different times, for different purposes, without a shared vocabulary. REACH needed a way for a non-EU substance manufacturer to satisfy registration duties without forcing every downstream EU importer to register separately, so it created the OR. CE-marking legislation needed a way for a non-EU manufacturer's conformity documentation to have an accountable EU-based point of contact, so various directives created the AR. GPSR needed a general product-safety contact independent of any specific product category, so it created the RP. Each solves its own regulation's problem — none of them substitute for either of the other two.
A seller assuming "we already have someone covering this in the EU" without checking which specific role that person holds is the single most common REACH-adjacent compliance gap this page exists to prevent — the disambiguation table above is the fastest way to check.
Three Roles, Three Regulations
Only Representative vs Authorised Representative vs Responsible Person
The confusion is real, and it isn't just terminology — each role sits under a different regulation, with a different scope and a different trigger for when it's needed.
| Only Representative | Authorised Representative | Responsible Person | |
|---|---|---|---|
| Legal basis | REACH, Article 8 | Product-specific CE-marking legislation | GPSR, Article 16 |
| Covers | Substance registration duties | Conformity-assessment and technical-file duties for a product category | General product-safety documentation and market-surveillance contact |
| Mandatory? | Optional — an alternative to EU importers registering individually | Optional unless the specific directive requires one | Mandatory for a non-EU manufacturer's consumer products |
| Can one party hold two roles? | Only if the written mandate for each role expressly covers it — not automatic | Same caveat | Same caveat |
Appointment
Who Can Be a REACH Only Representative
Requirements under Article 8
An OR has to be established in the EU or EEA and have sufficient practical background in handling substances and the information related to them — not a formality role, but one requiring real chemical-regulatory competence.
Ongoing duties once appointed
Keeping an up-to-date list of the EU importers in the substance's supply chain, retaining records of import quantities and uses, and managing the safety data sheets those importers need — an ongoing responsibility, not a one-time registration and done.
The REACH OR appointment itself is formalised through a written mandate between the non-EU manufacturer and the appointed party — the mandate is what makes the arrangement legally effective, not an informal agreement to handle registration.
The Liability Shift
What Actually Changes for Your EU Importers
This is the real reason ORs exist, not just an administrative convenience.
Importers become downstream users
Once an Only Representative is appointed for a substance, the EU-based importers who bring that substance in through the OR are treated as downstream users rather than registrants in their own right — the registration burden moves to the OR. (This reclassification is well-documented across REACH compliance guidance; verify the precise mechanics against Article 8(3) of the regulation itself before relying on it for a specific high-stakes decision, since the exact scope can depend on the supply-chain structure.)
Cost
REACH Only Representative Cost, by Component
OR service retainer
An ongoing fee for the OR's record-keeping and SDS-management role — ongoing because the duties themselves are ongoing, not a one-time registration task.
The registration fee itself
Paid to ECHA, scaled by the substance's tonnage band — the same registration-cost structure covered on our main REACH guide, since the OR is registering on the same fee schedule any other registrant would face.
Real Scenario
A Pattern Worth Checking Your Own Supply Chain Against
The importer who assumed an OR covered them automatically
A common pattern: an EU importer buys a substance from a non-EU manufacturer who mentions having "REACH covered" through an appointed Only Representative, and the importer assumes that statement alone satisfies their own compliance obligation. Whether the importer is actually covered depends on whether their specific supply-chain relationship is included in the OR's records — an OR appointed for one distribution channel doesn't automatically cover a different importer sourcing the same substance through a separate route. Confirming your specific import is named in the OR's records is the step that actually matters, not the manufacturer's general claim that an OR exists.
FAQ
Common Questions About the REACH Only Representative Role
What is a REACH Only Representative, in plain terms?
An EU-established party a non-EU manufacturer appoints to handle REACH substance registration on their behalf, so the EU importers in that supply chain don't each need to register the substance themselves.
Who can be a REACH Only Representative?
Any EU or EEA-established party with sufficient practical background in handling substances and the associated regulatory information — commonly a specialised REACH compliance service, though the regulation doesn't restrict it to a specific type of organisation as long as that competence requirement is met.
Is a REACH Only Representative the same as a REACH Only Representative vs importer situation — do I need both?
No — appointing an OR is specifically the alternative to each EU importer registering the substance individually. Once an OR is appointed and the relationship is properly recorded, the importer's role shifts to downstream user rather than needing its own separate registration.
How much does a REACH Only Representative cost?
Two components: an ongoing service retainer for the OR's record-keeping and SDS-management duties, plus the substance registration fee itself paid to ECHA, scaled by tonnage band — there is no single flat figure, since both components vary by substance and volume.
What are the REACH Only Representative requirements to actually qualify for the role?
EU or EEA establishment, and demonstrable practical competence in handling substances and their regulatory information under Article 8 — the role carries real ongoing duties (import-chain record-keeping, SDS management), so the competence requirement is substantive, not a formality.
Where the Facts Come From
Sources for This Page
Regulation (EC) No 1907/2006, Article 8 (Tier 1, EUR-Lex) is the legal basis for the Only Representative role. The downstream-user reclassification described above is corroborated by multiple REACH compliance sources but not independently verified word-for-word against Article 8(3) for this page — confirm the exact mechanics with ECHA's own guidance or a qualified REACH advisor before relying on it for a specific supply-chain decision.
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