REACH pre-registration

As the 1st of December 2008 deadline for general pre-registration has already passed, the only pre-registration function now available is for late pre-registration.

Late pre-registration

For a substance to be eligible for late pre-registration the substance must be what is known as a 'phase-in' substance. This means that:

• The substance is listed on EINECS, i.e. those on the EU market before 1981
• The substance was manufactured in the Community, or in countries acceding to the EU on the 1st January 1995 or on 1st May 2004, but not placed on the market by the manufacturer, at least once in the 15 years before entry into force of this Regulation, provided the manufacturer has documentary evidence of this. (Basically, these are substances that have been made in the EU but not placed on the market there. They will generally be site limited or export only substances. Evidence of this should be available if challenged)
• The substance is a so called 'no longer polymer'

In addition, it must be the first time that the substance has been imported or manufacutered in quantities of one tonne per year or more by the legal entity in question. This needs to be done within 6 months of the first import/manufacture and no later than 12 months prior to the appropriate registration deadline. This means it is already too late to pre-register any substances which have a 2010 deadline.

What do I need to do?

Pre-registration will mean informing the European Chemicals Agency (ECHA) of:

• The name of the substance as specified in section 2 of REACH Annex VI, this includes CAS, EINECS or other identification codes
• Name and address of the contact person or representative
• Envisaged deadline for the registration and the tonnage band
• Identifier information of any structurally similar chemical which you may wish to rely on to provide useful evidence on hazards as part of your registration package

You can do this by going to the IT portal on the ECHA webpages which will take you through the pre-registration process.

What happens next?

Once pre-registered the European Chemicals Agency put the late pre-registrant in contact with other pre-registrants of the substance. These will already be members of a 'Substance Information Exchange Forum' (SIEF) where they can negotiate sharing their available data and the costs of generating any new data required for registration. Further details on this can be found in the ECHA guidance note.

As a downstream user, how will I know the substance that I use has been pre-registered?

The ECHA has published a list of pre-registered substances on its website. This means that you can check that the substance that you use has been pre-registered. However, the list will only comprise the names of the substances, EINECS and CAS identification codes and the first registration deadline, it will not contain any details on who actually pre-registered the substance.

If the substance you use is not on the list, you should notify the European Chemicals Agency (ECHA), via the ECHA website, of your interest in this substance - giving your contact details and those of your current supplier. The Agency will then 'advertise' on their website for a registrant for the particular substance. If anyone comes forward to take on the responsibility they will be provided with your contact details as the downstream user of the substance.