Only representation offered to companies outside the EU

Compliance with REACH is mandatory for continued sales of chemicals and products in the European Union. ELC’s Only Representative service for REACH allows companies located outside the European Union to participate in REACH pre-registration and registration, whether registration is required for a single substance or a range of substances.

ELC’s Only Representative service guides companies located outside the EU through the pre-registration process for REACH and may also be extended to the registration process. The service provides the necessary legal presence and representation in the EU, including representation in the European Chemical Agency (ECHA); technical management of REACH pre-registration and registration; and submission of information to the EU to fulfil a company’s REACH obligations.


Only Representative Service for REACH pre-registration:

  • Power of Attorney granted to ELC, providing a legal presence in Europe to act on your behalf through the pre/registration process
  • Collection and submission of pre-registration data for each substance
  • Worldwide REACH expertise to support technical elements related to pre-registration
  • Submission of pre-registration of chemicals for REACH 1907/2006
  • On-call consulting support for all questions related to REACH for the duration leading up to pre-registration
    • Direct access to ELC’s REACH Experts HelpDesk
    • Unlimited Q&A for REACH-related questions
    • Real-time information change notices (ICNs) on legislative or industry changes on REACH
  • Submission of chemical information to the EU and the Substance Information Exchange Forum (SIEF)
  • Representation in SIEF
  • Corporate education and consulting support


Extended Only Representative Service for REACH registration:

  • On-call access to REACH experts for support of REACH registration related questions
  • Participation in the SIEF, including contact and coordination with SIEF members
  • Data exchange and evaluation
  • Negotiation with SIEF and Consortium members
  • Submission of registration applications
  • Collection and submission of technical dossiers
  • Creation and submission of material safety data sheets (MSDSs)
  • Creation and submission of chemical safety reports (CSRs) -where required
  • Authorized negotiations with ECHA
    • High-level discussions about risk assessments and use of information
    • Notification to the ECHA of quantities of products manufactured/imported and related risk assessments
  • Communication concerning substances to downstream users

 

ELC’s approach to REACH Services:
Phase 1 — Responsibilities and Pre-Registration

  • Analysis of key details related to
    • Sales channel
    • Supply chain
    • Products and chemicals
  • Determination of responsibilities
  • Determination of timelines
  • Creation of compliance strategy creation of decision tree
  • Pre-registration
  • Provision of education and on-call expert support


Phase 2 — Implementation and Compliance

  • Data Gathering
    • Program management
    • Data gathering from supply chain
  • Documentation & Testing
    • Registration Dossiers (Technical Dossiers)
    • CSR (Chemical Safety Reports)
  • SDS (Safety Data Sheet), eSDS (Extended Safety Data Sheet)
  • Testing of chemicals and substances including:
    • Physico-chemical testing
    • Toxicological testing
    • Eco-toxicological testing
  • Registration
    • Registration with the European Chemicals Agency (ECHA)
    • Notification of Substances of Very High Concern (SVHC's)
    • Formation of representation (for non-EU manufacturers)
  • Reporting
    • Reporting of ongoing requirements to European Chemicals Agency (ECHA)

 

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