Does an EU Only Representative appointment cover substance registration while leaving separate article duties with the importer?

Does an EU Only Representative appointment cover substance registration while leaving separate article duties with the importer?

The duties of an importer, a distributor or a downstream user sit with that party, and the company publishes no file for them.

Every commercial NanoFlashing™ product is made by a manufacturing partner, in their facility, in their format. The manufacturer and seller of a finished product are responsible for its design, manufacture, labeling, instructions, claims, sale, and warranty, except for a responsibility C-POLAR expressly accepts in a Separate Agreement. The Terms of Use state: “Accessing the Site or contacting C-POLAR through the Site does not create a partnership, agency, joint venture, distribution right, supply commitment, license, exclusive right, or other business relationship.”

For the filter, the company sets out its position in its own statement. The Statement of Regulatory Status for the NanoFlashing™ Air Filter, dated 11 September 2026, records how the company applies Article 3 of Regulation (EU) No 528/2012 to the filter, and states that it addresses that question only. It states at 3.4 that the filter is supplied as a finished article, that it is not a substance and it is not a mixture, and that the Regulation takes the meaning of “substance”, “mixture” and “article” from Regulation (EC) No 1907/2006. It states at 3.5 that the filter has not been treated with a biocidal product and does not incorporate one, and at 3.7 that the company classifies it as neither a biocidal product nor a treated article. A materials review that needs more than the position set out here is arranged in writing, through [email protected] on the Contact page.

Source: Statement of Regulatory Status for the NanoFlashing™ Air Filter, C-POLAR Technologies, Inc., 11 September 2026, sections 1.3, 3.4, 3.5 and 3.7; C-POLAR — Terms of Use, sections 5 and 6, https://cpolar.tech/terms/; C-POLAR — Contact, https://cpolar.tech/contact/.

Reviewed on 21 September 2026.