Only Representative Organisation

EU Legislative Interests

REACH is one of the most complex regulations. Public authorities do need the expertise and input of ORO members to better implement this regulation. The obligations of the Only Representative (OR) are defined in Art. 8 of the REACH Regulation. Accordingly, ORs are directly liable vis-à-vis the national and EU authorities with regard to their role. This liability, based on the Art. 8, represents the legal justification of our interest to be directly involved and recognized in public affairs related to REACH and CLP. Only Representatives (ORs) are covering more than 25% of all chemicals registered under EU REACH. Therefore, we enable non-EU manufacturers to keep their products on the EU market and by that assure that the EU meets the WTO criteria. We do cover thousands of non-EU manufacturers and support EU importers meeting the EU REACH and CLP obligations. Thus, as an Organisation we support the Commission and ECHA to ensure that interests of chemical manufacturers outside the EU are respected and such non-EU entities are not disadvantaged. The main EU policy areas followed by ORO are as follws: EU Chemicals Policy, including the Chemical Strategy for Sustainability (CSS); REACH Regulation; Regulation on Classification, Labelling and Packaging (CLP) Regulation; F-Gas Regulation; Cosmetics Regulation; Biocidal Products Regulation; Food Contact Regulations; Endocrine Disruptors; Nanomaterials; Restriction on Microplastics. The upcoming revision of the EU REACH Regulation as well as the Chemicals Strategy for Sustainability (as part of the Green Deal policies) are of utmost importance for the ORs to participate in the ongoing EU policy making processes and therefore we are deeply involved in the consultation process and providing feedback. Examples of successful lobbying activities are referenced below.

Communication Activities

ORs were not able to file Applications for Authorisations under REACH until we lobbied Member States, ECHA and the COM. Now non-EU manufacturers can file Applications for Authorisation via their ORs. ORs were not entitled to file group notifications under the CLP Regulation until ORO has made Member States, ECHA and the COM aware of this short-coming, requesting to allow so. Now it is possible. Interpretation of responsibilities of ORs for Safety Data Sheets was enforced differently in the EU Member States until we have engaged with ECHA and the Enforcement Forum. Now Guidelines are available at the ECHA Website, which we can refer to. Issuing different Position Papers. Issuing of Best Practice Guide (https://www.onlyrepresentative.org/wp-content/uploads/2023/06/ORO-Best-Practice-Guide-v2.0_2023_FINAL_06.2023.pdf). The BPG is available on the ECHSA Website too. ORO does participate in meetings with agencies/platforms related to chemical policy (e.g. ECHA, ECHA Committees, CARACAL, National Member State authorities). ORO is an accredited stakeholder of ECHA. Listing in the Transparency Register is a pre-requisite for accredited stakeholdership. A list of attended Meetings can be provided upon request.

Interests Represented

Promotes their own interests or the collective interests of their members

Member Of

We cooperate informally with: - Cefic (European Chemicals Industry) - Eurometaux (Metals Industry) - FECC (Traders in Chemicals) - CONCAWE (Petrochemical Industry).

Organisation Members

ORO Members and Partners are listed here: https://www.onlyrepresentative.org/members/

Additional Information

ORO is a low-budget organisation and raises its funds exclusively from membership fees. All activities of the board and the individual members are carried out on a voluntary basis without any remuneration. All Board Members serve under honorary appointment.