Selling chemicals in Europe under REACH, through your own only representative
Any chemical imported into the European Union at one tonne a year or more must first be registered with the European Chemicals Agency (ECHA) under the EU regulation on chemicals (REACH). Only a company established in the EU can make that registration. A manufacturer outside the EU therefore leaves the work to each of its EU importers, or appoints a single EU company, the only representative, to register on behalf of all of them. Your own Dutch company can take that role, which keeps the registrations, and the data behind them, inside your group.
Ask about your situationREACH, short for the registration, evaluation, authorisation and restriction of chemicals, requires a company to register a substance once it imports one tonne or more of it a year. The registration is filed with ECHA in Helsinki. A manufacturer outside the EU can appoint an only representative established in the EU, which registers the substance and takes over the duties of the EU importers, who then count as downstream users, the term REACH uses for companies that buy and use a chemical. We set up the Dutch company that can act as your only representative and importer, and work with REACH consultants on the registrations.
Hazardous products also need EU labels and safety data sheets, and a mixture with health or physical hazards must be reported to the poison centres. Your Dutch company can take on these duties as the importer.
Tell us what you make or sell, where your company is and what you plan in Europe. Our team looks at it and replies with the steps and the dates that apply to you.
Who does what
We set up and manage the Dutch company. Specialist partners do the licence and product work. We are your only contact, with one file for all the work.
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
The Dutch company
- Set up the Dutch company (a BV), by power of attorney, with the notary
- Registration number at the Dutch Chamber of Commerce (KVK), tax number and VAT number
- Bank account, the customs number (EORI) and the licence to settle import VAT in the VAT return (Article 23 licence)
- Bookkeeping, VAT returns, annual accounts and corporate tax
- Single point of contact for the REACH consultant and the terminal or warehouse
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 for mixtures
- Storage and handling at licensed chemical terminals and warehouses
- Status as authorised declarant under the EU carbon border levy (CBAM), where it applies to your goods
The steps to the European market
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 you ship to the EU, who your EU customers are and whether the substances are already registered, and you receive a suitable structure with a proposal.
- The Dutch company. The notary sets up the BV by power of attorney, with the parent company as shareholder. You receive the KVK number, the tax number, the VAT number and the customs number, and we prepare the bank application.
- The appointment. You appoint your Dutch company as only representative in a signed letter, and the REACH consultant sets up the ECHA account and the list of importers it covers.
- The registrations. Registrations held by a service company are transferred, and new substances are registered in the right tonnage band, through the joint submission where one exists.
- The labels. The partner classifies your products and prepares the EU labels, the safety data sheets for each country and, for mixtures, the poison centre notification with the unique formula identifier (UFI) code.
- Operations. Your product is stored in a Dutch terminal or warehouse and your own company sells to EU customers, while we file the VAT returns and keep the books. You receive one overview each month and deal with one contact person.
How REACH registration works
Under REACH, the company that brings a chemical into the EU must show that it can be used safely. 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 sets out the identity of the substance, its uses and its hazards, and from 10 tonnes a year it includes a chemical safety report. The data required depends on the volume band, with bands starting at 1 tonne, 10 tonnes, 100 tonnes and 1,000 tonnes a year.
Companies that register the same substance share their data in a joint submission. Registration fees are paid to ECHA, and the amount depends on the tonnage band and the size of the company. Substances of very high concern can require an authorisation before use, and some uses are restricted.
Mixtures are registered through the substances they contain. An article, such as a plastic part, is exempt from registration, although a substance inside it must be registered when it is meant to be released from the article in quantities over one tonne a year per importer (REACH, Article 7(1)). Articles that contain more than 0.1% of a substance of very high concern are reported to the ECHA database for such articles (SCIP).
The only representative
A manufacturer, formulator or article producer outside the EU may appoint one only representative in the EU. That representative must be a person or company 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, who become downstream users and are relieved of their own registration.
For the manufacturer, the result is one registration for the whole EU, where otherwise each EU customer would register separately. The manufacturer keeps control of the data and the tonnage, and its customers can buy the substance and skip a REACH registration 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. Those with steady EU sales, their own stock in Europe or their own sales office tend to give the role to their own Dutch company, so the group owns the registrations. The company can meet the knowledge requirement through an employee or a contracted REACH specialist.
Tell us what you make or sell, where your company is and what you plan in Europe. Our team looks at it and replies with the steps and the dates that apply to you.
Classification, labelling and poison centres
Alongside REACH, the EU regulation on classification, labelling and packaging of chemicals (CLP) requires the company that places a substance or mixture on the EU market to classify it and to label it with the EU pictograms and hazard statements. For a substance, that company also reports the classification to ECHA. For hazardous products, the supplier provides a safety data sheet in the language of each country of sale.
Mixtures with health or physical hazards that are sold to consumers, professionals or industry must be reported to the poison centres before sale, through a single EU portal at ECHA for the poison centre notification (PCN). The unique formula identifier (UFI) code is printed on the label. Because the notifying company is the EU importer or downstream user, a Dutch company that imports for you files that notification.
Why the Netherlands for chemicals
Rotterdam is the largest port in Europe, and its port area is one of the largest centres of the European chemical industry, with refineries, tank storage and bulk terminals at Botlek and Maasvlakte. From Rotterdam, companies supply the chemical industry in Germany and Belgium by barge on the Rhine, through pipelines or by motorway. Bureau REACH, part of the National Institute for Public Health and the Environment (RIVM), is the Dutch helpdesk and the authority responsible for REACH and CLP. Inspections are carried out jointly by the Human Environment and Transport Inspectorate (ILT), the Netherlands Food and Consumer Product Safety Authority (NVWA) and the Netherlands Labour Authority.
As only representative and importer, a Dutch company has the customs number, the Article 23 licence and the VAT registration. Import VAT at 21% on a €1 million shipment comes to €210,000. With the licence, your company declares this amount in the VAT return and deducts it in the same return, so it skips the payment at the border. Corporate tax is 19% on the first €200,000 of profit and 25.8% on profit over that amount, and dividends the company pays to a parent company in a country with a tax treaty are usually free of Dutch dividend tax.
Steel, aluminium, cement, fertilisers and hydrogen also fall under the EU levy on the carbon content of imports, the carbon border adjustment mechanism (CBAM), in addition to REACH. Since 1 January 2026, an importer of more than 50 tonnes a year of steel, aluminium, cement or fertilisers must be an authorised CBAM declarant established in the EU. For hydrogen, the rule applies from the first unit. Read CBAM and the authorised declarant.
Based on Regulation (EC) 1907/2006 (REACH), Regulation (EC) 1272/2008 (CLP) and Regulation (EU) 2023/956 as amended by Regulation (EU) 2025/2083 (CBAM). Also based on the guidance of ECHA and Bureau REACH at the RIVM, as applied in September 2026. Specialised partners prepare the registrations, and we coordinate their work.
Common questions
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Related guides
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