Within the REACH-EN-FORCE-3 project, coordinated by the European Chemicals Agency’s (ECHA) Enforcement Forum in cooperation with national enforcement authorities in 28 countries inspected 1,169 companies and 5,746 substances in 2013 and 2014. The aim was to investigate the registration obligations of manufacturers, importers and only representatives.

In total, 13 % of companies did not fulfil some of their registration obligations. In most of these cases, the non-compliant companies failed with registration duties related to one or two substances from their portfolio. 2 % of companies had not registered any substances at all.

Only representatives, who register substances on behalf of importing downstream users, are more likely to be in breach of their REACH-related obligations than other registrants. The flow of information in the supply chain between only representatives and importing downstream users was poor. It was often difficult to establish the structure of the supply chain as the respective importers could not specify the correct only representative and the only representatives did not keep reliable records of represented importers.

ECHA’s Executive Director Geert Dancet thinks that “The high non-compliance rate for only representatives and importers needs to be addressed by these types of companies and their stakeholder organisations”.

• European Chemicals Agency (ECHA), Helsinki, Finland
• Forum REACH-EN-FORCE 3 – Final Report, ECHA, Helsinki, Finland, 2015.