Who is responsible for the registration in case of import?

In case of import the registration should be made by the legal entity established in the EU who is responsiblle for the import. The responsibility for import depends on many factors such as who orders, who pays, who is dealing with the customs formalities.

Only representative of “ non-community manufacturer ”

Registration of substances imported into the EU on their own, in preparations or in certain cases in articles, will have to be submitted by the EU importers. This implies that each individual importer needs to register the substance(s).

 
Natural or legal persons that manufacture substances, formulate preparations or produce articles outside the EU cannot by themselves register a substance(s). 

However, although not responsible for any action under REACH, they can nominate an only representative established within the EU to carry out the required registration of the substance that is imported into the EU. This will relieve the EU importers within the same supply chain from their registration obligations, as they will be regarded as downstream users of the only representative.