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REACH Preregistration

As part of a phased registration process, manufacturers and importers were offered the opportunity to pre-register 'phase-in' substances (i.e. existing chemical substances with an EINECs number) during the period 1st June to 1st December 2008. Pre-registration allows companies to continue manufacturing and importing their phase-in substances for several years until the registration deadline is reached and ensures an extended timetable for registration with the earliest deadline being December 2010 (for very high volumes or particularly harmful substances).

A list of all pre-registered substances is now available on the ECHA website (http://apps.echa.europa.eu/preregistered/pre-registered-sub.aspx). This list allows you to identify potential registrants of the same substance for the purpose of data sharing (SIEF participation).

Missed pre-registration? Don't despair, you may be eligible for late pre-registration

If your phase-in substance is manufactured or imported for the first time after 1st December 2008 in quantities of 1 tonne or more per year, you will be eligible for late pre-registration, provided you do so:

  • at the latest 6 months after manufacturing or importing a substance above the 1 tonne threshold per year; and
  • at least 12 months before the relevant transitional deadline for registration.

Not eligible for pre-registration? Or do you have a new substance?

As of 1st June 2008, new chemical substances (termed 'non-phase-in') must be registered before they can be manufactured or imported in the EU. Before submitting a registration, you must submit an Inquiry Dossier to ECHA in order to find out whether another company has already registered the substance or submitted an inquiry dossier. If so, ECHA will provide you and the other party with each other's contact details to facilitate the data sharing process and proceed with a joint registration.

The Inquiry Dossier must contain:

  • contact details;
  • information on substance identity; and
  • a list of relevant information requirements and whether any new studies are required (dependent on tonnage bands).

Need assistance preparing your late pre-registration or registration dossiers?

IOM's REACH experts will carefully tailor advice to your needs in order to help you through the registration process. Our range of services includes: