Changing Your Only Representative: What Happens to Your REACH Registrations?

This article refers to EU REACH throughout. You can also change your Only Representative under UK REACH. The process follows similar principles, but transfers are managed through the UK’s Comply with UK REACH service rather than ECHA’s REACH-IT system. ACRE acts as an Only Representative and support manufacturers with OR transfers under both EU and UK REACH.

Changing your Only Representative (OR) does not mean starting your EU REACH registrations again.

Manufacturers supplying chemicals into the EU may decide to change their OR for several reasons. Perhaps their current provider no longer meets their needs, they want more technical support, or they are reviewing how their REACH obligations are managed.

Whatever the reason, a common concern is what happens to existing registrations when changing ORs.

Under EU REACH, existing registrations can generally be transferred to a new OR without having to register the substances again.

However, the transfer needs to be planned and coordinated between the parties involved.

Can you transfer EU REACH registrations to a new Only Representative?

Yes. EU REACH allows a non-EU manufacturer to replace its existing OR and transfer the associated registrations to the newly appointed representative.

The transfer is managed through the legal entity change functionality in ECHA’s REACH-IT system.

Provided the transfer requirements are met, the incoming OR can take over the existing registrations without repeating the original registration process.

The manufacturer, outgoing OR and incoming OR will need to agree which registrations are being transferred and coordinate the process.

What information needs to be transferred?

A REACH registration involves more than a registration number. The incoming OR needs sufficient information to maintain the registrations and fulfil the associated regulatory obligations.

This typically includes:

• Registration details: Registration numbers, substance identities and current registration dossiers.
• Technical information: Supporting studies, substance identity data and relevant technical documentation.
• Customer and tonnage records: Details of importers covered by the OR arrangement and the quantities imported.
• Data access arrangements: Letters of Access, data-sharing agreements and consortium memberships, where applicable.
• Regulatory correspondence: Relevant communications with ECHA and other regulatory parties.
• Outstanding obligations: Pending dossier updates, compliance checks or other regulatory activities.

The exact information needed will depend on the substances and existing arrangements. It is also important to check that the incoming OR has the necessary rights to access and use the supporting data.

Does your existing Only Representative need to cooperate?

Under ECHA’s standard process, the outgoing OR initiates the transfer in REACH-IT and the incoming OR accepts it.

This means it is important to establish how the transfer will be managed before terminating the existing arrangement.

Manufacturers should review their agreement with the outgoing OR, particularly any provisions relating to termination, information access and the transfer of registrations.

If the outgoing OR cannot initiate the transfer, for example because it has ceased trading, ECHA may need to be contacted for guidance.

What should you check before changing ORs?

Before transferring your EU REACH registrations, it is worth checking whether the existing records accurately reflect your current activities.

Are all relevant substances covered? Are customer and import volume records up to date? Are there outstanding dossier updates or regulatory requests?

Changing ORs is also an opportunity to review how your registrations are being maintained and identify any gaps in the information held.

Not every outstanding issue needs to be resolved before the transfer. However, the incoming OR should understand what it is taking responsibility for, and any unresolved matters should be documented.

How do you manage an OR transfer?

The main steps are to confirm the new appointment, review the existing registrations, arrange access to the necessary information and coordinate the transfer through REACH-IT.

The manufacturer should also inform the importers covered by the OR arrangement so they know who is responsible for their EU REACH compliance and can confirm their imports remain covered.

Planning the handover before the existing arrangement ends helps reduce the risk of gaps in regulatory coverage or missing information.

Thinking about changing your Only Representative?

ACRE provides EU and UK REACH Only Representative services, including support for manufacturers moving from an existing provider.

We can review your current arrangements, identify the information needed and help coordinate the transfer. Contact ACRE to discuss your existing arrangements.

Frequently Asked Questions

1. Can I change my Only Representative without losing my REACH registrations?

Yes. Existing EU REACH registrations can generally be transferred from your current Only Representative to a new provider through ECHA’s REACH-IT system. You do not normally need to register the substances again, provided the transfer requirements are met.

2. How long does an Only Representative transfer take?

The timeline depends on the number of registrations, the information available and how quickly the outgoing and incoming ORs can coordinate the transfer. It is worth starting discussions before your existing agreement ends to allow time for the necessary checks and handover.

3. Will I need to pay ECHA fees to transfer my registrations?

ECHA generally charges an administrative fee for a legal entity change, including a change of Only Representative. The applicable fee and any additional costs should be confirmed before proceeding. Your existing OR agreement may also contain provisions relating to transfer or termination costs.

4. Do my EU customers need to do anything when I change ORs?

Your EU customers should be informed of the change and given the details of the new OR. They should also have confirmation that their imports remain covered by the relevant registrations. This helps avoid uncertainty about their regulatory status following the transfer.

5. What happens if my current Only Representative refuses to transfer my registrations?

The standard REACH-IT transfer process requires the outgoing OR to initiate the transfer. If your existing OR is unwilling or unable to cooperate, you may need to contact ECHA to discuss the available options. Reviewing your existing agreement and establishing access to registration information early can help identify potential difficulties.