REACH pre-registration - what do I need to do?

When can I pre-register my substance?

The first major new REACH activity for manufacturers/importers of substances is pre-registration. In order for the company to take advantage of this activity 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 substance 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 must be available)
• The substance is a so called ‘no longer polymer’

If the above applies to any of the substances a company imports or manufactures then they can pre-register the substance from the 1 June 2008 to 1 December 2008.

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 ECHA webpages which will take you through the pre-registration process.  If you have large numbers of substances to pre-register you can  download IUCLID 5 in order to prepare all these files.

What happens next?

Once pre-registered the European Chemicals Agency will identify who is intending to register the same substance and put them in contact with each other. The potential registrants can then come together and form a 'Substance Information Exchange Forum’ (SIEF) where they can negotiate sharing their available data and the costs of generating any new data. 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 will publish a list of pre-registered substances on its website by the 1 January 2009. 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 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) 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.