Supporting our non-EU customers with the Dow Only Representative Trustee
EU companies that import products - either directly or indirectly - have to comply with all of the obligations of importers under REACH. In order to make it easier for our non-EU customers to continue to sell to their customers in the EU, Dow has developed the Only Representative Trustee (ORT).
The Dow ORT is an independent third party that can administer all business confidential data, such as the identity of customers in the EU and their individual volumes, for the Dow Only Representative. This offers our non-EU customers the opportunity to have their EU importers' registration obligations for Dow indirect imports met by the Dow Only Representative instead.
With 'Dow indirect imports', we mean Dow products (substances, preparations or polymers) that are manufactured or formulated outside the EU and then sold to non-EU customers of Dow before being imported by EU companies into the EU (as such or in formulations). These Dow products are 'Dow indirect imports' for those EU companies.
Coverage of EU importers' registration obligations through the Dow ORT can be offered for those indirectly imported Dow products for which coverage can be included in the registration dossiers Dow will file for its own imports.
Field Fisher Waterhouse (FFW) has been selected to operate as Trustee in the Dow ORT model. The Field Fisher Waterhouse (FFW) portal serves as the central clearinghouse for information on the Dow ORT, including instructions on how to submit a formal request for participation
