OR: do and don’ts
What an OR could do and what he can't
23 Jun 2020A shortlist about what the OR could and couldn't do:
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DO |
DON'T |
|---|---|
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The OR can cover indirect imports, when for example non-EU distributors do exist in the supply chain between the manufacturer/formulator and the EU importer. |
The OR is not recognized by CLP Regulation and cannot then fulfil duties that are defined by this legal act. |
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The OR must keep an up-to-date list of EU importers within the supply chain of the non-EU represented and the tonnage covered for each of these customers. |
A non-EU manufacturer/formulator cannot appoint more than one OR per substance. |
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The non-EU represented can change his OR over time. |
In case a group established outside the EU is composed of several companies, a single appointment cannot link the OR to the whole group. The OR can be appointed by each of the companies if they wish, but he needs to submit different registration dossiers. |