Chemicals · EU market entry

Chemicals in Europe: REACH, the only representative and your own company

A chemical that enters the EU in a volume of one tonne a year or more must be registered with the European Chemicals Agency. Only a company established in the EU can register it. Either every EU importer registers, or the manufacturer appoints one only representative in the EU that registers for all of them. Your own Dutch company can be that representative.

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In short

The EU regulation on chemicals is called REACH, for registration, evaluation, authorisation and restriction of chemicals. Substances that enter the EU at one tonne or more a year per company must be registered with the European Chemicals Agency (ECHA) in Helsinki. A manufacturer outside the EU appoints an only representative (OR) that is established in the EU. The only representative registers the substance and takes over the duties of the EU importers, who then count as downstream users. Holdwise sets up the Dutch company that can be your only representative and importer, and works with REACH consultants for the registrations.

On this page: how registration works, what the only representative does, the labelling and poison centre rules, why the Netherlands, and the steps to the first shipment.

1 tonne

per year per registrant: above that, a substance needs a REACH registration

ECHA

the European Chemicals Agency in Helsinki holds the registrations

import VAT at the border with the Dutch deferment licence (Article 23)

How REACH registration works

REACH puts the burden of proof on the company that brings a chemical into the EU. Every substance at one tonne a year or more per registrant must be registered before it is made in the EU or imported. The registration contains the identity of the substance, its uses, its hazards and, above ten tonnes, a chemical safety report. The data requirements grow with the volume band: one to ten tonnes, ten to a hundred, a hundred to a thousand, and above a thousand.

Companies that register the same substance share data through a joint submission. Registration fees go to ECHA and depend on the tonnage band and the size of the company. Substances of very high concern can need an authorisation before use, and some uses are restricted.

Mixtures are registered through their substances. Articles, such as a plastic part, are registered when a substance is meant to be released from them, and articles that contain a substance of very high concern above 0.1% are notified in the SCIP database of ECHA.

The only representative

A manufacturer, formulator or article producer outside the EU may appoint one only representative in the EU. The only representative is a natural or legal person established in the EU with sufficient knowledge of the practical handling of substances. It registers the substances in its own name and takes over the obligations of the EU importers of those substances. The importers become downstream users and no longer need their own registration.

That is the whole point for the manufacturer: one registration for the EU, where otherwise each customer registers, control over the data and the tonnage, and customers who can buy without a REACH burden of their own. The only representative keeps a list of the importers it covers and the tonnage each of them imports.

Many manufacturers use a service company as only representative. A manufacturer with steady EU sales, its own stock in Europe or its own sales office puts the role in its own Dutch company. The registrations are then owned by the group. The chemical knowledge the law asks for can be an employee or a contracted REACH specialist.

Classification, labelling and poison centres

Alongside REACH there is the regulation on classification, labelling and packaging of chemicals (CLP). The company that places a substance or mixture on the EU market classifies it, labels it with the EU pictograms and hazard statements, and notifies the classification to ECHA. Hazardous products come with a safety data sheet in the language of each country of sale.

Hazardous mixtures sold to consumers, professionals or industry are notified to the poison centres before sale. The EU does that through one portal at ECHA, the poison centre notification (PCN), with a unique formula identifier (UFI) code printed on the label. The notifying company is the EU importer or downstream user, so a Dutch company that imports for you does that notification.

Why the Netherlands for a chemical entry

The port of Rotterdam is Europe’s largest port and one of its largest chemical clusters, with the refineries, tank storage and bulk terminals at Botlek and Maasvlakte. From there the Rhine, the pipelines and the motorways reach the chemical industry in Germany and Belgium within hours. The Dutch helpdesk and competent authority for REACH and CLP is Bureau REACH at the National Institute for Public Health and the Environment (RIVM). The Human Environment and Transport Inspectorate (ILT) inspects.

A Dutch company as only representative and importer holds the customs number, the Article 23 licence and the VAT registration. Import VAT on a €1 million shipment at 21% is €210,000; with the licence it is reported in the VAT return and paid to nobody. Corporate tax is 19% on the first €200,000 of profit and 25.8% above that. Dividends to a parent company in a treaty country usually go out without Dutch dividend tax.

If your products are steel, aluminium, cement, fertilisers or hydrogen, the carbon border adjustment mechanism (CBAM) applies on top of REACH. Since 1 January 2026 an importer of more than 50 tonnes of those goods a year must be an authorised CBAM declarant, which must be established in the EU. Read CBAM and the authorised declarant.

Based on Regulation (EC) 1907/2006 (REACH), Regulation (EC) 1272/2008 (CLP), Regulation (EU) 2023/956 as amended by Regulation (EU) 2025/2083 (CBAM) and the guidance of ECHA and Bureau REACH at the RIVM, as applied in September 2026. Registrations are prepared by specialised partners; Holdwise coordinates.

Who does what

Holdwise sets up and runs the Dutch company and stays your single point of contact. Specialist partners do the licence and product work. You keep one contact, one file and one invoice.

You

Your company

Own the substances, the formulas and the manufacturing data
Provide the substance identity, the analytical data and the safety data
Decide which importers and countries the only representative covers
Sign the power of attorney and the appointment of the only representative

Holdwise

The Dutch base

Sets up the Dutch company (a BV), by power of attorney, with the notary
Registered office, KVK number, tax number and VAT number
Bank account, the customs number (EORI) and the Article 23 licence
Bookkeeping, VAT returns, annual accounts and corporate tax
Single point of contact for the REACH consultant and the terminal or warehouse

Specialist partner, via Holdwise

Licences and product rules

The REACH registrations, the joint submissions and the dossier updates
The only representative appointment letter and the importer list
Classification and labelling, safety data sheets, the poison centre notification
Storage and handling at licensed chemical terminals and warehouses
CBAM declarant status where your goods fall under it

The route, step by step

What happens from your first question to the day your first product is on the European market.

One question. You tell us what you make, the volumes to the EU, who your EU customers are and whether the substances are registered already. We answer in writing with the structure that fits and one written proposal.
The Dutch company. The notary sets up the BV by power of attorney with the parent as shareholder. You receive the KVK number, the tax number, the VAT number and the customs number. The bank file starts on day one.
The appointment. You appoint your Dutch company as only representative in writing. The REACH consultant sets up the ECHA account and the list of covered importers.
The registrations. Existing registrations by a service company are transferred; new substances are registered in the right tonnage band, with the joint submission where one exists.
The labels. Classification, EU labels, safety data sheets per country and the poison centre notification with the UFI code.
Operations. Product in a Dutch terminal or warehouse, sales to EU customers from your own company, VAT and bookkeeping done. One monthly overview, one point of contact.

Related guides

The other parts of the route to Europe, on the same site.

CBAM and the authorised declarant: the EU entity

Which EU representative does your product need?

A Dutch trading entity for commodities

Importing in bulk through the Netherlands: customs and VAT

Setting up a subsidiary in Europe

Corporate services: address, bookkeeping, VAT and payroll

Common questions

Can my own Dutch subsidiary be my only representative? +

Yes. The law asks for a natural or legal person established in the EU with sufficient background in the practical handling of substances. A subsidiary meets the first part through its Dutch registration and the second part through an employee or a contracted REACH specialist. The registrations are then owned inside your group.

Do my EU customers still need their own REACH registration? +

When your only representative covers a customer, that customer counts as a downstream user of the registered substance. The only representative keeps the customer on its importer list and tracks the tonnage.

What if I sell less than one tonne a year? +

Below one tonne a year per substance there is no registration duty. Classification, labelling, safety data sheets and the poison centre notification still apply to hazardous products at any volume.

Can I move my registrations from a service company to my own company? +

Yes. A registration can be transferred to a new only representative through ECHA, with a change of legal entity. The consultant prepares it; the old and the new representative both confirm.

Does the UK have its own REACH? +

Yes. Since 2021 Great Britain has UK REACH, separate from EU REACH. A company that sells in both needs both. The Dutch company covers the EU and the European Economic Area.

Does Holdwise do the REACH registrations? +

Holdwise sets up and runs the Dutch company that takes the role, and coordinates the partners. The registrations, the classification and the notifications are done by REACH consultants we work with. You keep one contact: us.

What does the Dutch company cost? +

The setup starts from €2,950 excluding VAT, notary included. Running it means a registered address, bookkeeping with VAT returns, the annual accounts and the corporate tax return. We put the whole amount in one written proposal before you decide. The REACH consultant quotes per substance.

Ask about your own situation

Tell us what you make or sell, where your company is and which countries you want to sell in. You get a written answer. Where a Dutch company fits, we write down what it would look like and what it costs.

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