The REACH Trustee Service has developed a new web-based system to efficiently track substances through complex supply chains and provide quantity import data to Only Representatives for registration purposes. The system allows non-EU manufacturers to enter their products, then invite downstream customers to also enter export sales to the EU without disclosing confidential information. This overcomes prior difficulties of gathering such data while complying with competition laws. The system is advantageous as it demonstrates commitment to customers, eases their REACH burden, and ensures low-cost compliance.

1. Non- EU
Manufacturer
Non-EU
Customer
EU-ImporterSubstance
Formulation
with the
substance
EU
Outside EU
OR
Introduction
An Only Representative (OR) for a non-EU manufacturer can relieve EU importers from their
registration obligations under REACH, provided the OR maintains a record of the quantities being
supplied to the EU importer. This process is often referred to a “registering within the supply chain”.
For substances that are supplied directly to the EU this is a straight forward process as the non-EU
manufacturer has this information readily available. However, if the supply chain outside the EU is
more complex (e.g. the non-EU manufacturer sells his substances to a non-EU entity such as a
formulator, trader or a polymer manufacturer) and these non-EU actors sell to the EU, there would
be an issue in how the non-EU substance
manufacturer would legally be able to
obtain the volume and import destination
details for his OR. Gathering information
(product composition, customer details etc.)
through the supply chain would jeopardise
CBI (Confidential Business Information) and
likely breach competition / antitrust laws, so
generally this is advised against.
This problem can be overcome by
downstream actors reporting their export
data to a third party or Trustee (such as a
Law Firm). This is typically a manual process which is very time consuming, complicated and can be
expensive.
The REACH Trustee Service’s new web-based system has been developed to provide an elegantly
and efficiently solution to this problem, enabling the non-EU manufacturers’ sponsored substances
to be tracked effortlessly through the complex supply chain and data on quantities being importer
into the EU to be provided to the OR, while protecting CBI. The REACH Trustee Service allows the EU
importer to take full advantage of registration in the supply chain enabling compliance with REACH
and competition / antitrust laws.
How the system works
1. The non-EU manufacturer (which we term the Sponsor) opens an account on the REACH
Trustee services system and then they enter their products on to the data base.
2. The non-EU manufacture invites his non-EU customer to join the system who then sets up
their products on the system.
3. The non-EU customer enters on the system all sales of products into the EU.
4. Steps 2 and 3 are repeated for successive levels in the supply chain.
5. The Sponsor or their OR can interrogate the system at any time and obtain reports on the
volumes of their substances that are exported to the EU through the complex supply chain

2. (they will not get customer details but that information would be made available to any
competent authority if required).
The advantage for the Non-EU Manufacturer
• Demonstrates to all customers that you are a committed supplier of the chemicals
• Is an elegant and efficient solution that conveys a level of professionalism commensurate
with your image as a market leading company committed to excellence in business
processes
• Reduces the REACH compliance burden on your customers which can be seen as a form of
Enhanced Product Stewardship that will add value to your product offering distinguishing
your products in the marketplace and ensuring enhanced customer loyalty
• Meets all REACH Compliance as well as Competition /Antitrust law requirements
• Low costs compared to all other systems
• Easy to set up, with actors down the supply chain in-putting their data so work burden is
shared.
Fee Structure
• The Sponsor will be responsible for the fee through the complex supply chain. The Sponsor
will also control the level of sponsorship supported within the supply chain.
Why we do not invoice all the customers in the supply chain?
• The supply chain believes this approach is consistent with suppliers supporting their
products and customers (product stewardship ethos).
• The low level of administration burden from the invoicing process means that we the total
cost is kept to a very low level, making the System economical to use for everyone, ensuring
a high up-take of the system.
• The customers dependent on registration within the supply chain will show greater loyalty
to their preferred suppliers enabling price adjustment that would easily outweigh the cost of
maintaining the system.