Only Representative (OR)

An Only Representative (OR) is a legal person established in the EU who is appointed by a non-EU manufacturer to fulfil registration obligations under REACH on behalf of EU importers of the manufacturer’s substances. Under Article 8, when an OR is appointed, EU importers of the represented substances become downstream users and are relieved of registration obligations for those substances. The OR registers with ECHA, maintains the registration, and reports EU importers to ECHA.

REACH Regulation (EC) No 1907/2006, Article 8.

Non-EU manufacturers can appoint an OR to provide a streamlined registration pathway for the entire EU market. An OR can represent multiple non-EU manufacturers for different substances but must keep the identities of represented importers confidential from competitors. Once an OR is registered, EU importers sourcing that substance from the represented manufacturer are treated as downstream users and do not need to register. EU importers must verify whether an OR has been appointed to avoid duplicate registration obligations.