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REACH Pre-Registration
1 June 2008 - 1 December 2008
Manufacturers and importers (or an 'Only Representative') must pre-register substances that are already on the EU market (phase-in substances) if they want to benefit from transitional arrangements that allow registering them at a later stage. After pre-registration, potential registrants will have until December 2010, June 2013 or June 2018 (depending on tonnage per year and other criteria) to register. If a manufacturer or importer fails to pre-register a phase-in substance, he will need to register it before continuing manufacture or import. REACH Timeline - click here
Pre-registration also enables registrants to share data with other registrants and avoid carrying out redundant tests.
Pre-registration also enables registrants to share data with other registrants and avoid carrying out redundant tests.
| The pre-registration period is now over. If your company starts manufacturing or importing 1 tonne or more of a chemical substance per year after 1 December 2008 you can benefit from late pre-registration provisions. Late pre-registration does not apply to companies that failed to meet the pre-registration deadline. These companies cannot continue producing or importing the substance until they have submitted a full registration dossier. REACH-IT will be enabled for submission of late pre-registrations from 5 January 2009. |
What is required for pre-registration?
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substance name
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potential registrants details (or 3rd party representative)
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deadline for registration
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similar substances
How is this data submitted?
- Agency form on website
A list of all pre-registered substances will be published on the ECHA website by 1 January 2009. This list will facilitate the identification of potential registrants of the same substance for the purpose of data sharing. Pre-registrants will be put in touch with each other.
Pre-registration is not a legal requirement of REACH but is strongly advised.
Preparing for Pre-Registation
1. Create an inventory of the substances you manufacture / import / use;
2. Prioritise
3. Improve Communication Links and Build Relationships
Establish a relationship with your suppliers and any downstream users. You need to know how REACH is going to impact on your supply chain before you can decide what to do about it. Identify an appropriate person as the main REACH contact in your organisation and make them the focus for communications with suppliers and customers.
- Build an inventory of every chemical that comes into, is part of, or goes out of the business. BPF members are able to access and utilise the EuPC inventory tool for free;
2. Prioritise
- Consider the importance of each substance to your business.
- What do you use it for?
- Are the uses to which you put chemicals going to be supported by their registrants?
- How much of it do you use?
- Are there any alternative substances or processes that could replace this?
- Will your supplier/s maintain supply of important substances if REACH impacts the commercial viability of doing so?
- What will be the impact for you if the price increases or the supply drops, and what can you do about it?
- Do you want to share information back to registrants about what you use chemicals for, or is this information so sensitive that you would prefer to compile risk assessments yourself, and submit these directly to the European Chemicals Agency? What will this involve?
- Identify any chemicals that may be 'substances of very high concern'
- Determine your role in relation to each substance on the inventory
3. Improve Communication Links and Build Relationships
Establish a relationship with your suppliers and any downstream users. You need to know how REACH is going to impact on your supply chain before you can decide what to do about it. Identify an appropriate person as the main REACH contact in your organisation and make them the focus for communications with suppliers and customers.
