Whether a sole representative (OR) can act on behalf of importers to notify producers outside the EU about classification and labeling (C&L) substances has been a point of contention within the European Chemicals Agency (ECHA) and the European Commission.<\/p>\n\n\n\n
However, on May 3, ECHA issued a statement on its official website indicating that it would accept classification and labelling (C&L) notifications from suppliers other than manufacturers and importers as required by the CLP Regulation. This change means that sole agents (ORs) who are not importers can finally submit C&L notifications on behalf of non-EU companies. Previously, ORs needed to import small quantities of chemical substances to qualify as importers before they could submit classification and labelling notifications.<\/p>\n\n\n\n
EHCA is currently adjusting the REACH-IT system interface to allow non-importer collaborating organizations (including ORs) to also conduct group notifications. This adjustment is expected to be completed by the summer of 2012. In the coming weeks, ECHA will update relevant guidance manuals and support documents.<\/p>\n\n\n\n
ECHA also emphasizes that if the OR submits classification labels on behalf of a company (including manufacturers and importers), the OR must provide documentation proving that it is authorized by the company to submit the C&L notification on behalf of the manufacturer or importer; simultaneously, the manufacturer or importer must commit to fully fulfilling its responsibilities related to notification. Furthermore, all documents related to the manufacturer or importer, along with the information required for the C&L notification, must comply with the requirements of national law enforcement agencies and other relevant law enforcement agencies.<\/p>\n\n\n\n
Prior to ECHA's official statement, the operational model for ORs to submit classification and labeling notifications on behalf of companies mostly involved companies providing representative samples of substances and mixtures to the OR. The OR could then act as the importer, responsible for import matters, and conduct C&L labeling notifications. Once ECHA's IT system was adjusted and the new REACH-IT was released, the OR only needed to provide the necessary authorization letter and a commitment letter from the company to represent a group of companies in further C&L notification work.<\/p>\n\n\n\n
Sources: ECHA official website news<\/a> \u3001ECHA Notification Regarding CLP<\/a> (2012-05-03) (Compiled by PIDC)<\/p>","protected":false},"excerpt":{"rendered":" \u552f\u4e00\u4ee3\u7406\u4eba (Only Representative, OR) \u662f\u5426\u80fd\u5920\u4ee3\u66ff\u9032\u53e3\u5546\uff0c\u70ba\u6b50\u76df\u5883\u5916\u751f\u7522\u5546\u9032\u884c\u7269\u8cea\u5206 […]<\/p>","protected":false},"author":1,"featured_media":0,"comment_status":"open","ping_status":"closed","sticky":false,"template":"","format":"standard","meta":{"_acf_changed":false,"footnotes":""},"categories":[79],"tags":[],"class_list":["post-5233","post","type-post","status-publish","format-standard","hentry","category-echa"],"acf":[],"yoast_head":"\n