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Practical sheet | REF: FIC0144 V1

Importing a substance into the EEA, determining who is responsible for placing it on the market within the meaning of the REACh regulation

Author: Gautier VINCENT

Publication date: July 10, 2011, Review date: October 4, 2016 | Lire en français

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3. Distributors importing substances and mixtures

If you go through a distributor located in the EEA who buys a substance from outside the EEA, the person responsible for the import may be that distributor or you. Only a case-by-case analysis will provide an answer. Important information includes

  • the importer ;

  • the legal entity mentioned on the invoice ;

  • the ability to source outside the EEA ;

  • the address of the first delivery in EEA.

For example:

  • If you don't know that your distributor buys his substance outside the EEA, the importer may be the distributor as a natural person.

  • If you have asked the distributor to purchase a substance that is not available on the European...

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