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

Based on the inventory, you can identify the substances you import. To do this, you need to know your supplier’s country.

If the supplier is based in the European Economic Area (EEA), you are not responsible for placing the purchased substance on the market. You are a downstream user under the REACH Regulation.

If your supplier is not based in the EEA, you are responsible for importing the product into the European market. Since importing is automatically considered to be placing the product on the market, you are responsible for placing the product on the market.