REACH Registration Obligation
If you import products into the EU and offer them for sale, whether via Amazon FBA or your own online shop, there is no way around the REACH Regulation. REACH is one of the strictest chemicals regulations in the world and does not only apply to chemical manufacturers, but to anyone importing products into the EU that contain chemical substances.
In two earlier blog posts, we explained the basics of the REACH Regulation to you (see here: Part 1 and Part 2).
Today, we are taking it one step further, to an area that is extremely important for Amazon sellers: the REACH registration obligation from 1 tonne per year and the crucial role of the Only Representative.
Many companies are not even aware that, from a certain quantity onward, they are legally required to have substances registered with ECHA, and that without the correct registration, import stops, warnings, or complete sales bans may suddenly become a real risk.
This blog post tells you what you need to pay attention to, what risks exist, and how you can best protect yourself as a manufacturer or importer.
Why REACH is relevant for you
The REACH Regulation, Registration, Evaluation, Authorisation and Restriction of Chemicals, is the central EU regulatory system for chemicals.
It applies to:
- substances on their own
- substances in mixtures
- substances that can be released from articles
Why is this relevant for you as an Amazon seller or e-commerce seller?
Because almost all imported products contain some kind of chemical substances: plastics, paints and coatings, adhesives, batteries, metals and surface coatings, textiles, electronic components, fragrances, and much more.
As soon as a substance is brought into the EU in a quantity of 1 tonne per year, the registration obligation applies.
This applies to:
- brand owners who manufacture abroad
- sellers who import products from non-EU manufacturers
- companies that have goods delivered into Europe
Even small Amazon brands can reach this threshold with just a few thousand units per year, for example with household goods or plastic toys.
The registration obligation under REACH
REACH registration is not optional, it is a legal obligation.
When does the registration obligation apply?
As soon as the annual import or manufacture of a substance exceeds 1 tonne, that substance must be registered with ECHA.
This applies to:
- substances on their own, for example isopropanol
- substances in mixtures, for example cleaning chemicals or paints
- substances that are intentionally released from articles, for example scented candles or dehumidifiers
When are there exceptions?
Certain substances are exempt from registration, for example:
- natural substances, under certain conditions
- polymers, although the monomers may still need to be registered
- medicinal products
- certain intermediates
For all other substances, the rule is: From 1 tonne onward, registration is required.
Why non-EU companies face a problem
If your company is based outside the EU, for example in Switzerland or the UK, you face a fundamental problem: you cannot register the substance yourself.
Only companies based in the EU/EEA are allowed to carry out REACH registrations.
What does this mean for you?
Risk 1: The importer automatically becomes responsible for registration
Risk 2: Access to the EU market may be lost
Product safety is not ensured without REACH compliance. This can result in a sales ban in the EU, a suspension of your Amazon listings, or recalls and fines.
Risk 3: Chaos in the supply chain
Without a clear REACH status, your logistics partner has no legal certainty, and without legal certainty there can be no stable supply relationship.
The role of the Only Representative
For non-EU companies, the solution, apart from establishing their own EU branch, is the Only Representative (OR). The Only Representative is the bridge between your company and European regulation.
Who can act as an Only Representative?
An Only Representative must:
- have a registered office in the EU/EEA
- have proven expertise in chemicals, substance data, REACH, and safety data sheets
- be contractually appointed
Why is this important?
- You reduce the burden on your importers and logistics providers, they do not have to take over the registration.
- You retain full control over your compliance.
- You secure your access to the EU market and avoid suspensions on Amazon.
- You can sell your products via FBA or other channels without risk.
For many sellers based outside the EU, the OR is the only way to import legally into the EU.
Duties of the Only Representative
An Only Representative takes over all REACH obligations that would otherwise fall on your importer or logistics provider.
This includes registration with ECHA.
The OR prepares:
- substance identity profiles
- technical dossiers
- exposure scenarios
- tonnage reports
- data sets on toxicological and ecotoxicological properties
Preparation and maintenance of safety data sheets
The OR must:
- prepare SDS in EU format
- update them when new data becomes available
- ensure that suppliers receive the SDS
Communication with authorities
This includes:
- follow-up questions from ECHA
- submission of additional data
- annual tonnage reports
- inspections and audits
Monitoring quantities
The OR monitors the quantities of your imports and ensures correct reporting.
Advantages for sellers
Appointing an Only Representative offers clear advantages for you as an e-commerce seller with a registered office outside the EU.
1. Secure market access
You do not need your own EU branch, yet you remain fully REACH-compliant.
2. Relief for importers
Your importers and logistics partners do not need to take on complex and costly registrations or documentation.
3. Professional compliance
An OR is an expert in REACH, something logistics providers can almost never offer.
4. Competitive advantage
Many brands lose market access because they ignore REACH, you do not.
Practical tips for implementation
To implement REACH correctly and smoothly, you should keep the following points in mind:
1. Choose the right Only Representative
Make sure that your OR:
- has real expertise
- has experience with ECHA registrations
- handles quantity management professionally
- works on a clean contractual basis
- communicates transparently
2. Make sure the contract contents are clear
The contract should specify:
- which substances must be registered
- who provides the data
- how imported quantities are monitored
- how importers are informed
- how technical changes are communicated, for example new suppliers or new formulations
3. Start early
The registration must be completed before the product is placed on the market, meaning before your goods arrive in the EU.
Registrations can take months, so plan realistically.
4. Keep your supply chain clean
If you source different components from different countries, make sure you obtain substance data for all components.
Conclusion
The REACH registration obligation from 1 tonne per year affects far more companies than many people think. Amazon sellers in particular are responsible here, and without correct registration they risk losing access to the EU market.
This also applies to sellers with a registered office outside the EU. With a professional Only Representative, you too can cover all REACH obligations properly, safely, and efficiently. Your importers and logistics partners are relieved, and your products remain marketable in the long term.
Who wrote this article?
As an author, Christina fills the blog section of our website with exciting and informative articles, so that our readers can always take care of product compliance in their company in the most well-informed way.
