Importer

Under REACH Article 3(11), an importer is any natural or legal person established within the EU who is responsible for the import of substances, mixtures, or articles into the EU customs territory. EU importers bear the same registration obligations as EU manufacturers: substances imported above 1 tonne per year must be registered by the importer unless they are registered by a non-EU manufacturer’s Only Representative. Importers of articles must comply with Article 33 and Article 7(2) notification obligations for SVHC-containing articles.

REACH Regulation (EC) No 1907/2006, Article 3(11) and Articles 6–8.

EU importers of chemicals must register substances before import (or verify that the non-EU manufacturer has appointed an Only Representative who has registered). For articles, importers must screen all imported goods for Candidate List SVHCs above 0.1% w/w, notify ECHA under Article 7(2) if the 1-tonne annual threshold is met, and communicate SVHC presence to customers under Article 33. Brexit meant UK-based entities ceased to be EU importers; EU-based affiliated entities or new Only Representatives must be designated.