How to Apply to the REACH System

How to apply to the REACH system

REACH governs chemical substances produced in the EU and imported into the EU from non-EU countries. The EU only deals with natural and legal persons established within the EU and does not deal directly with manufacturers based outside it. Manufacturers and exporters in Turkey fall into the non-EU manufacturer category. Direct applications to the EU are not available to Turkish firms, so two alternatives exist for registration in the REACH system and for continued exports to the EU.

The first route is for an EU-based importer to register the chemical substances it imports from Turkey under its own name. In that case, the importer has the same standing as any EU manufacturer. To prepare the registration file for the Turkish manufacturer and exporter, the importer needs the full set of information (regardless of confidentiality level) from the Turkish firm. A notable downside of this route is that the importer gains access to all the information about the chemical substance. Importers are also often reluctant to take the registration burden onto themselves, given the length of the registration and bureaucratic process.

The second route is for Turkish manufacturers or exporters to appoint an Only Representative. The Only Representative can be a natural or legal person established in the EU. Within the system, the Only Representative becomes the sole point of contact for other EU-based parties. Under REACH, EU firms will not accept Turkish firms as direct counterparties. The representative registers the substances the firm wants to export on its behalf and becomes the single responsible party under REACH. In this setup, the importer is treated as a downstream user and can request the Chemical Safety Report (CSR), Chemical Safety Assessment (CSA), Safety Data Sheet (SDS), Exposure Scenario (ES), and similar reports, documents, and information from the Only Representative rather than produce them.

How Sistem Patent Kalite supports REACH applications

Sistem Patent Kalite supports both routes: importer-led filings where the Turkish firm cooperates with the importer, and Only Representative arrangements with an EU-based representative. The team manages the documentation, coordinates with the representative, and keeps the exports moving.