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UK REACH Only Representative
If you manufacture outside Great Britain, UK REACH places no duty on you. It places the duty on every GB customer who imports from you — which is why they will eventually ask you to solve it, or find a supplier who has. An Only Representative is how you solve it.
- Who appoints one
- A manufacturer, formulator or article producer established outside Great Britain
- Who can act
- A natural or legal person established in Great Britain with sufficient background in the practical handling of substances
- Effect
- The OR registers as if it were the importer; your GB customers are treated as downstream users
- Appointment
- By written mandate from the non-GB manufacturer. One OR per legal entity, covering named substances
- What it does not cover
- EU REACH, Northern Ireland, or GB CLP notification duties, each of which is separate
Why this matters commercially
Without an OR, every GB customer importing your material above one tonne a year must register it themselves. That means each of them individually paying HSE fees, acquiring data access, and building a dossier for a substance they did not make.
Most will not do it. They will consolidate onto a supplier who has already removed the problem. This is the mechanism by which non-GB manufacturers quietly lose the British market without ever being told why.
Without an Only Representative
Five GB customers importing your substance means five separate registrations, five sets of fees, five dossiers — and five commercial reasons to switch supplier. Your tonnage is also fragmented, so smaller buyers may fall below the threshold while larger ones carry a disproportionate cost.
With an Only Representative
One registration covers the volume you place through that OR. Your customers become downstream users with no registration duty. You control the dossier, the data and the substance identity — and you can say so in a tender.
What an Only Representative actually does
The role is not a mailbox. An OR takes on the legal obligations of an importer, and is accountable to HSE for them.
- Submits and maintains the UK REACH registration in its own name, on your behalf.
- Holds and keeps current the information on the quantities imported and the customers supplied.
- Keeps available the latest updated safety data sheets and supplies them down the chain.
- Informs your GB importers that they are covered, so they can evidence their own downstream user status.
- Handles correspondence, evaluation decisions and data requests from HSE.
- Updates the dossier when tonnage bands change, or when new hazard information emerges.
An OR is only as good as its records
The obligation to track quantities and customer lists is a real one, and it is the first thing examined if coverage is ever questioned. An OR that registers a dossier and then goes quiet exposes both you and your customers. Ask any prospective OR how it maintains volume records and how it notifies your importers of their covered status.
How appointment works
Scope
We confirm which substances need covering, at what tonnage, and whether any are exempt.
Mandate
You issue a written appointment. We accept in writing and the relationship is documented for HSE.
Registration
We build and submit the dossier, or bring across an existing one where the route allows.
Maintenance
Volume tracking, customer notification, SDS distribution and dossier updates, for as long as the mandate runs.
Points that are commonly misunderstood
| Assumption | Position |
|---|---|
| "My EU Only Representative covers Great Britain." | No. An EU OR acts under EU REACH. Great Britain requires a GB-established OR under UK REACH. Northern Ireland is covered by the EU appointment, not the GB one. |
| "One OR can cover our whole group." | The mandate runs from a specific non-GB legal entity. Separate manufacturing entities need separate appointments. |
| "We can appoint several ORs for the same substance." | A manufacturer appoints one OR per substance for a given market. Splitting creates untraceable volume and is not accepted practice. |
| "The OR owns our data." | It should not. Insist the mandate states that the dossier, the studies and the letters of access remain yours, and that they transfer on termination. |
| "Appointing an OR also handles classification." | GB CLP notification is a separate duty. Confirm explicitly whether your OR is doing it. |
| "Our distributor can be the OR." | An OR must be appointed by the non-GB manufacturer, not chosen by a GB buyer, and it must be independent enough to hold the legal obligations properly. |
Choosing an OR you can leave
The appointment is a long relationship built on a dossier that only has value if you can take it with you. Before signing with anyone, including us, get written answers on three things: who owns the dossier and the data, what happens to them on termination, and what the annual maintenance fee covers.
We act as Only Representative from our London office. The mandate we use states that the registration dossier, all study data and all letters of access acquired on your behalf remain your property and transfer to you or to a successor OR on termination. We will send you the wording before you commit to anything.
General information on the Only Representative role under UK REACH. Whether an appointment is the right structure depends on your supply chain and customer base — tell us how you sell into GB and we will say so plainly.