REACH - Information for Notifiers of New Substances

As of June 1st 2008 NONS has been replaced by REACH and notifiers responsibilities under the NONS regulations are repealed.

• Directive 2006/121/EC of the European Parliament and of the Council

Substances that have been notified under NONS and have a recognised notification number have been transferred into REACH and are regarded as already having been registered (at the relevant tonnage band).

Claiming a REACH registration number

Each notification will be assigned a registration number by ECHA by Dec 1st 2008. A notifier can claim their REACH registration number from the Agency (via the REACH IT system). This functionality is now available, see the following from ECHA for details:

• Request a registration number for a notified substance under Directive 67/548/EEC

The following information is required:

• Notification number (compulsory)
• ELINCS number (compulsory) -  This can be obtained from: EC number for a UK notification
• Notifier name (compulsory)
• Notifier City (compulsory)
• Notifier Country (compulsory)
• Remarks (optional) - explanations, justifications, why the company details in the REACH-IT sign-up are different than those in the notification (eg. Change of address or company name, newly appointed OR…)

Certain documentation is also required for Only Representatives.

Provided that the claimant's details match those of the notifier the Agency will provide the registration number. If the details do not match, further verification will be required by the Agency/member state competent authority (MSCA).

If the details do not match, you will be informed and are advised to contact your Member State Competent Authority. If this occurs please ONLY contact us using the following e-mail address: newsubs.uk@hse.gsi.gov.uk

When doing this, please provide;

1. Date of claim attempt
2. Information inputted (exact wording is important)
3. Error message received
4. If there is a change in company – all relevant paperwork to explain changes (as required by ECHA)

Please note that even small typing errors may cause the claim to be rejected or a company name may not have been amended and we therefore advise you to try alternatives before contacting us.

Update - IUCLID 5 files for notified substances

The UK REACH CA has now received the migrated IUCLID 5 files for all UK NONS notifications.

To request your migrated SNIF file(s), please contact the new subs account (newsubs.uk@hse.gsi.gov.uk) with the following information;

• NONS notification number(s)
• REACH registration number(s) (please see above for details on claiming)
• Contact details (company name, address, contact person, e-mail & phone number)
• Preferred delivery option (* see below)
• Where applicable, an OR appointment letter

Before distribution we will need to confirm a claimant’s entitlement to the file(s) therefore, if there are any changes to the notifier details we have on file please provide an explanation with supporting evidence where applicable.

* Delivery options;

• e-mail
• CD by recorded delivery (only to UK addresses)
• Courier delivery UK & overseas (claimant to arrange at own expense)

Status of notified polymers under REACH

Substances notified in accordance with Directive 67/548/EEC are regarded as registered by the manufacturer or importer who submitted the notification (Article 24(1)). The registration requirements under Title II are therefore covered by the notification in the tonnage band for which the notification was made. The registration of the monomers or other substances from which the notified polymers are derived is not required.

As soon as the manufactured/imported quantity of polymer reaches the next tonnage threshold, the registration requirements (Title II of REACH) as described in this guidance should be followed for the monomer(s) or any other substance(s) meeting the conditions of Article 6(3).

Updating registrations

Article 22 of the REACH regulation lists the further duties of registrants, specifically when an updated registration should be submitted to the Agency.

When the next REACH tonnage threshold is reached the notifier/registrant will need to comply with the relevant requirements for that level under REACH [Article 24].

Outstanding information for NONS notifications

If additional information was required for your NONS notification, this should be submitted to ECHA as an update to your dossier (in IUCLID 5 format) following normal ECHA procedures.