Gujarat Castor Oil Exporter Appoints EU Only Representative and Grows EUR 6M EU Revenue

Curated by Vinod Kumar Jain & Amit Jain · All Frontier Global · free, no login

India-EU

Challenge

A Gujarat-based castor oil producer and processor was exporting castor oil to EU cosmetic manufacturers without awareness that their EU importers were required to register the castor oil substance under REACH. When the EU importers raised this issue, several threatened to switch to registered Brazilian castor oil suppliers. Annual EU castor oil revenue of EUR 4.2M was at risk.

Solution

AJG facilitated engagement with a Netherlands-based REACH Only Representative service provider. The OR took responsibility for REACH registration of castor oil (HS 1515.90, CAS 8001-79-4) on behalf of the non-EU manufacturer. REACH registration had already been submitted by a European industry consortium (CONCAWE-affiliated) for fatty acids including castor oil derivatives — the OR identified that castor oil at <1 tonne/year per importer could use SIEF (Substance Information Exchange Forum) membership rather than full registration. All EU importers were briefed on the REACH compliance solution.

Outcome

REACH compliance established for all 7 EU importers within 4 months. No EU buyers switched to Brazilian suppliers. Annual EU castor oil revenue grew from EUR 4.2M to EUR 6.1M over 2 years as the REACH compliance status became a competitive advantage (Brazilian competitors also had to register). OR annual fee: EUR 12,000 — far less than the threatened EUR 4.2M revenue loss.

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