The only actors in the supply chain with registration obligations are:

EU manufacturers and importers of substances on their own or in preparations.
EU producers and importers of articles meeting the criteria explained in the Guidance for articles.
“Only Representatives” established in the EU and appointed by a manufacturer, formulator or article producer established outside the EU to fulfill registration obligations of importers

Guidance on Registration – ECHA – May 2008

Companies that manufacture substances, formulate preparations or produce articles outside the EU cannot by themselves register a substance
Technical aspects will normally be pushed back on the supplier by the customer

This document is provided for information purposes only and does not constitute legal advice. While every effort has been made to ensure the accuracy of the information contained herein, The Lubrizol Corporation cannot be held liable for any errors in or any reliance upon this information.

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