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Reichhold REACH
What has Reichhold done outside the EU to prepare for REACH?

Non-EU manufacturers and formulators do not have any direct obligations under REACH.
It is the European importer of non-EU manufactured, who must comply with the requirements of REACH. However, non-EU manufacturers or formulators exporting products within scope of REACH may appoint an "only representative" to fulfill the registration obligations of EU importers.

Reichhold, Inc., Reichhold do Brasil Ltda., and Reichhold Quimica de Mexico, S.A. de C.V. which manufacture products outside the EU, have appointed Reichhold UK Ltd. as their Only Representative.
Reichhold UK Ltd. has pre-registered various substances to allow continued import of selected products and quantities into the EU by designated European importers pursuant to separate agreement. We anticipate that such products will continue to be available in the EU through the applicable registration deadlines.

As the last deadline approaches, we are pro-actively reviewing the volumes and import routes into Europe to determine appropriate action for compliance.
This may require
  • REACH Registration of some monomers or chemicals,
  • management of volume limitations or
  • adjustments to supply chain

By a non-EU manufacturer or formulator appointing an only representative, importers within the EU become downstream users and are relieved of their registration obligations for the quantities of substances contained in the agreed Reichhold products. The only representative is responsible for compliance with registration requirements and communication with downstream users. The only representative must also keep available and up-to-date information on the quantities of substances imported into the EU.
Non-EU manufacturers or formulators who incorporate Reichhold products into their own products which are imported into the EU, and EU importers desiring to benefit from Reichhold's OR appointment must first contact Reichhold's REACH coordinator to discuss their import quantities, understand their roles, and reach agreement with Reichhold regarding their respective obligations.

Notwithstanding the above, non-EU Reichhold affiliates such as Reichhold, Inc., Reichhold do Brasil Ltda., and Reichhold Quimica de Mexico, S.A. de C.V. reserve the right to take whatever action regarding their products as they deem appropriate, including, but not limited to, withdrawing a product from the EU market, instructing their OR to terminate a pre-registration or registration, or exclude a particular use in a substance's registration dossier. Each Reichhold non-EU affiliate will take reasonable steps to inform its direct customers and importers within the EU should one choose to terminate the pre-registration or registration of any substance comprising one of its non-EU products.

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