ECHA finally allows Only Representatives to submit C&L notifications.
6 May 2012, The European Commission has finally announced that Only Representatives (ORs) appointed under the REACH Regulation are allowed to submit group C&L notifications on behalf and in the name of the manufacturers/importers that are part of the group. This update is of particular importance to non-EU companies who wish to keep their ingredient information confidential. This news is also important to EU importers because they might not need to do C&L notifications by themselves any more.
It shall be noted that if the C&L notification is submitted by a third party on behalf of a group of manufacturers/importers, the submitting company will need to be able to document that it has been mandated to act on behalf and in the name of the manufacturers/importers that are part of the group and that the manufacturers/importers acknowledge that they remain solely and fully responsible for fulfilling all their obligations associated with the notification. The documentation related to the creation of this group of manufacturers/importers together with the data and information on which the C&L is based, may need to be made available on request to the national Competent Authorities or to the relevant Enforcement Authorities.
ECHA's press release can be found here.
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