The European Chemical Regulation REACH (EC/1907/2006) requires importers to pre-/register imported substances, unless the importer is considered to be a downstream user. This is the case if the imported volume is covered by an Only Representative (OR) appointed by the non-EU manufacturer of the imported substances on their own or in a preparation.

REACH does not distinguish between direct and indirect imports into the EU. Therefore, non-EU business followed by export to EU is more complicated – in particular if several non-EU steps along the supply chain are involved and substances have been formulated into preparations with confidential composition. In a multi-level non-EU supply chain the manufacturer of a substance usually does not know through which channels, in which products and finally how much volume of his substances is being imported into the EU. It is an essential business secret (CBI) of traders or formulators what the components of their products and who their suppliers and customers are. Neither the non-EU manufacturer (represented by the OR) nor the importer can fulfill their obligations without disclosing CBI and potentially leading to loss of business.

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