After the REACH SI was laid, Defra received representations from industry about the transitional import provision. Industry was concerned that, as drafted, it would still lead to disruption in the supply chain in the case of substances imported from outside the EEA. Industry was also concerned that the provision did not allow a REACH Only Representative to send the required notification to the UK Agency. REACH Only Representatives are UK-based entities appointed by non-UK manufacturers, formulators or producers to fulfil the obligations of importers under the REACH Regulation. The EU REACH Regulation contains an equivalent provision regarding EEA-based REACH Only Representatives. While industry has not provided detailed evidence of the impact, the Government has decided to reduce the risk through this instrument.
