Your REACH Only Representative for non-EU substance manufacturers

REACH registration, step by step

Every substance manufactured in or imported into the EU at 1 tonne or more per year per registrant must be registered with the European Chemicals Agency (ECHA) before it is placed on the market - "no data, no market" (Articles 5 and 6 of REACH).

Regulation (EC) No 1907/2006 From 1 tonne per year One substance, one registration Submitted in REACH-IT

Who registers

The obligation falls on the EU manufacturer or the EU importer of the substance. A manufacturer established outside the EU cannot register itself, but it can appoint an Only Representative under Article 8 to register on behalf of its EU importers, who then become downstream users.

The steps

1

Identify the substance

Establish substance identity (composition, impurities, analytical data) and the annual tonnage that will enter the EU.

2

Inquiry to ECHA

Ask ECHA whether the substance is already registered and who the existing registrants are, so you can join the joint submission.

3

Data sharing

Agree access to the lead registrant's data - usually by buying a Letter of Access - under the data-sharing rules of Implementing Regulation (EU) 2016/9.

4

IUCLID dossier

Prepare your member dossier in IUCLID with substance identity, tonnage band, uses and a reference to the joint data.

5

Submit in REACH-IT

Submit the dossier and pay the ECHA fee. ECHA runs a completeness check before a registration number is issued.

6

Keep it up to date

Update the registration when tonnage band, uses, classification or composition change.

Joint submission: one substance, one registration

Companies registering the same substance submit jointly (Article 11). A lead registrant submits the shared data on hazards and classification; the other registrants (members) submit their own company-specific information and refer to the joint data. Most commercial substances are already registered, so a new registrant is almost always joining an existing joint submission rather than building a dossier from scratch. See SIEFs and Letters of Access.

What drives time and cost

Frequently asked questions

What is the REACH registration threshold?

1 tonne per year per manufacturer or importer. Below that, registration is not required, although other REACH and CLP obligations can still apply.

Can a non-EU company register under REACH itself?

No. Registration is done by an EU manufacturer or importer, or by an Only Representative established in the EU and appointed by the non-EU manufacturer under Article 8.

Do I need to build a full dossier if the substance is already registered?

Usually not. You join the existing joint submission as a member registrant, typically by buying a Letter of Access to the lead registrant's data.

What happens after submission?

ECHA checks the dossier for completeness and, once the fee is paid and the check passes, issues a registration number. ECHA may later evaluate the dossier and request more information.

Related guides

Note: This guide provides general information about Regulation (EC) No 1907/2006 (REACH), not legal advice. Specific obligations depend on your substance, tonnage and supply chain. Last reviewed 30 September 2026.

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