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Taiwan -21/07/2008
REACH: Only Representative Rules Change Again

No. 27/2008 A non-EU manufacturer of a substance which is exported into Community territory 'indirectly' by a non-EU formulator (which uses that substance in its preparation) can appoint an OR to register the tonnage exported by that formulator.
The latest (May 2008) ECHA guidance on registration suggests that a non-EU manufacturer may appoint an OR to register tonnages of a substance exported by its non-EU distributor. However, that guidance does not make clear whether the non-Community manufacturer could appoint an OR where such export was made by a formulator. The Commission has now clarified that it can. It appears that this applies both where the non-EU manufacturer also exports the same substance directly to Community and where it does not.
Non-EU manufacturers that decide to change the OR they have appointed for a particular substance can submit an update to the ECHA and do not need to submit an entirely new registration dossier.
The latest (May 2008) ECHA guidance on registration states that the newly appointed OR would have to submit a new registration dossier. However, it appears that the Commission has now returned to its previous position stated in an earlier guidance (June 2007) that the new OR can, in agreement with the former OR, simply update the registration dossier.
REACH Pre-Registration Pre-registration of substances under REACH started on 1 June 2008 and ends on 1 December 2008. Substances on their own, in preparations or in articles which are not pre-registered during that period cannot be manufactured in the EU.
Information Source
Mondaq News
ECHA Pre-registration News SGS Taiwan LTD. Taipei Multi Chemical Laboratory t: +886 2 2299 3279
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