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Pre-Registration

Pre-registration allows companies to take advantage of the transitional deadlines in REACH.

These transitional deadlines are applicable to phase-in substances. A phase-in substance is one which:

Is listed in the European Inventory of Existing Commercial Chemical Substances (EINECS)
Is a no-longer-polymer (NLP)
Was manufactured in the EC, but not placed on the market by the manufacturer or importer, at least once in the 15 years before the entry into force of this Regulation, provided the manufacturer or importer has documentary evidence of this

Phase-in substances need to be pre-registered by the following deadlines:

30 November 2010

Substances manufactured/imported ³1000 tonnes/annum
Substances classified as CMR Category 1 or 2 ³ 1 tonne/annum
Substances classified as R50/53 ³ 100 tonnes/annum
   

31 May 2013

Substances imported/imported ³100 tonnes/annum
   

31 May 2018

Substances imported/imported ³1 tonnes/annum

To take advantage of these transitional arrangements, all eligible substances must be pre- by 30 November 2008. After this date any substances manufactured/imported in quantities ³ 1 tonne/annum may only be imported into the EU if they have been fully registered.

A company that has a legal entity in the EC must do pre-registration.  If a company does not have a legal entity in the EU they may appoint a company to represent them, called an Only Representative company (again must be based in the EC).  It is important to choose a company that is commercially independent, to protect your intellectual property and will be around for at least the next 10 years to represent you for REACH-related issues.


Pre-registration is carried out through the European Chemicals Agency, based in Helsinki.  The pre-registration procedure is simple if all the relevant information is available:

Name, address and contact details of company pre-registering the substance
Product name;
CAS number;
EC number;
If the substance is a multi-constituent substance you will also need
Constituent names;
Percentage of each constituent in the substance
Quantity exported to the EC per annum/expected registration deadline

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