Importing from outside the EU: who must notify?
Direct answer: The EU-based importer is the notifier. A manufacturer outside the EU cannot submit a notification themselves; they can only prepare information for you, or submit a voluntary notification through an EU representative so you can reference their UFI.
What to ask the manufacturer for
- Full composition with concentrations, or at least the SDS plus the missing non-hazardous components
- The classification according to CLP (not GHS as applied in another country; categories differ)
- Toxicological data for section 11
- If they will not disclose composition: a voluntary PCN submitted via an EU entity, giving you a UFI to reference as a mixture-in-mixture
Label and SDS
You also need an EU-format SDS in the local language and a CLP-compliant label with the UFI. The notification and the SDS must match; produce both from the same data.
Multiple importers
If several EU companies import the same product, each is a notifier for the countries it serves. The manufacturer's voluntary notification can make this cheap for everyone.