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REACH and Toll

Under REACH a ‘Toll manufacturer’ is defined as a company that manufactures a substance (on its own, in a mixture or in an article) in its own technical facilities following the instructions of a third party in exchange for compensation. The substance is generally put on the market by the third party. Where manufacture occurs is key to what steps must be taken to achieve compliance.

In terms of responsibility for a substance registration, it is likely that this would fall on the EU-based toll manufacturer, as they are responsible for the production or extraction of the substances in the natural state within the EU/EEA.

We can support both non-EU toll manufacturers by becoming your ‘Only Representative’ and EU toll manufacturers by acting as your ‘Third Party’ representative in the registration process ensuring that you meet your regulatory obligations.