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Non-EU Implications

REACH directly applies to the European manufacturer and importer of chemicals and chemical containing products and requires them to demonstrate the safety of their products put into the European markets by submitting detailed information on the intrinsic and toxicological properties of the products to the central chemical agency (ECHA). Therefore, it is but natural that the EU importer shall ask his Indian supplier to furnish the required information and this is how the Indian exporters get implicated within REACH. If the Indian exporters wish to continue uninterrupted trade with the EU, they shall have to collect all the information, as required within REACH for submitting to the ECHA.

It is important to note that submission of information to ECHA cannot be done by the Indian exporters. It can either be done by the European importer provided he is willing to act as the registrant or if he refuses to take this responsibility and in certain cases, if the Indian exporter does not wish to share proprietary information relating to his products, he shall have to appoint an “only representative”. The “only representative” is the only legal entity authorized to pre-register on behalf of the Indian exporter.

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