At the core of the REACH Regulation is the requirement that all substances imported into the European Union (EU) must first be registered with the European Chemicals Agency (ECHA). REACH, however, prescribes that only a company established in the EU can register. This requirement raises important compliance questions for multinational company groups with multiple non-EU entities importing substances into the EU—whether traders or manufacturers. In such cases, the EU-based group companies can register their substances, while the group companies based outside the EU cannot register their substances themselves. This article examines the three options open to non-EU companies to secure the registration of its substances.
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