REACH for non-EU manufacturers

REACH applies to manufacturers based outside the European Economic Area (EEA) and exporting chemicals into the EEA. Here are the key points to remember:

REACH (Registration, Evaluation, Authorization of Chemicals) is a significant regulatory system for chemicals management in Europe. It applies to all chemical substances entering the EEA and requires all manufacturers and importers of chemical substances (pure substances or mixtures or products using them) based in the EEA to register their substances with the European Chemicals Agency (ECHA). For more information on REACH, click here.

Rely on your importer or your “OR” to register and comply by the law
Manufacturers based outside of the EEA cannot register directly with ECHA. The responsibility for registering lies with their EEA-based importers or with their appointed “Only Representative” (“OR”).  By law, the “OR,” which can be an organization or individual, must be established within the EEA and must be knowledgeable about the substance or preparation exported to the EEA.

Failure to have an “OR” or the importer correctly register the substance will result in them being out of compliance with the REACH regulation and potentially exposed to fines or other enforcement actions by local authorities. This may result in the product being forbidden to enter the EEA and a negative impact on your business.

Registration needed or not?
As a global supplier, ExxonMobil has registered most of its fluids, plasticizers and chemical intermediates grades that it currently manufactures. However, whether our customers need to register the substances they purchase from us and that they plan to export to the EEA depends on the situation:

1.  Export ExxonMobil substance manufactured in the EEA (i.e., Belgium, the Netherlands or the UK), either as pure substance, as part of a preparation or as part of an article: 
        - Customers do not have to register the substance, but they must be able to provide proof of its origin at any time. We can provide the necessary letter or certificate.

2.  Export ExxonMobil substance manufactured outside the EEA (i.e., in the U.S. or Singapore) either as a pure substance, as part of a preparation or as part of an article:
        - Customers’ importers or “ORs” must register the substance, whether or not ExxonMobil has registered it independently.

Our Substance Information Profiles (SIPs) enable our customers to save registration time and hassle
For customers who must register a substance, we provide a comprehensive document called a Substance Information Profile (SIP) which contains relevant product information:
•  The naming convention that will identify under which category the substance should be registered;
• Complete substance analytical results: composition details, gas chromatography (GC) and ultra violet (UV) results, etc.;
• A dedicated contact person at REACH Centrum (created to help companies prepare and implement REACH) to personally assist in the registration process.
This valuable document will facilitate the registration process. Please contact your ExxonMobil sales person to get the SIP.

To ensure that importers remain in compliance with REACH, ExxonMobil strongly advises customers to consult with their appropriate regulatory experts or counsel to determine what actions may be appropriate to continue exporting to the EEA.

The Cefic paper on imports in the EU provides additional information about the REACH registration process and illustrates possible organizational options for non-EEA manufacturers.

Compare REACH and similar chemical management programs
To see similarities and differences between EU REACH and the chemical management programs in force in Turkey, South Korea and Taiwan, click here

Other obligations for downstream users
For other downstream users’ obligations, please click here and read our dedicated page.

Page glossary

  • Article
  • CEFIC
  • EEA
  • EU
  • Plasticizers
  • Preparation
  • REACH
  • Regulation
  • Substance
  • UV
  • WHO