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REACH Compliance

REACH Registration: No Data, No Market

"There is a general obligation for manufacturers and importers of substances to submit a registration to the Agency for each substance manufactured or imported in quantities of 1 tonne or above per year. Failure to register means that the substance is not allowed to be manufactured or imported."

- From the European Commission REACH Guidance Document of Feb 2007

REACH Registration: Who shall register

EU manufacturers/importers of substances over 1 tonne/year;
Only representative appointed by non-EU companies;

REACH Registration: What to register

- Substances manufactured/imported above 1t/y on its own or in preparations;
- Substances in articles if present above 1 t/y and intended for release;
- Monomer substances if present at a concentration above 2% in a polymer;
- Intermediates - reduced requirements;
- Substances subject to Product and Process Oriented Research and Development(PPORD ) exempted from registration for 5 (+ 5) years;
- Exemptions: polymers, Annex IV & V, radioactive substances, waste and re-imported substances
- Note: Cosmetics are not exempt from REACH registration.  Read More..

REACH Registration: When to register

Substances can be categorized into two groups: phase-in substances and non phase-in substances.

Phase-in substances("existing substances") enjoy benefits of varied extended registration deadlines if pre-registered before Dec 2008. The principle is that the higher the tonnage is, the earlier the registration deadline is. Substances classified as CMR1/2 need to be registered before 30 Nov 2010.

Phase in substance

A substance which meets at least one of the following criteria:

- It is listed in the European Inventory of Existing Commercial Chemical Substances (EINECS).
- It was manufactured in the Community, or in the countries acceding to the European Union on 1 January 1995 or on 1 May 2004, 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.
- It was placed on the market in the Community, or in the countries acceding to the European Union on 1 January 1995 or on 1 May 2004, before entry into force of this Regulation by the manufacturer or importer and was considered as having been notified in accordance with the first indent of Article 8(1) of Directive 67/548/EEC but does not meet the definition of a polymer as set out in this Regulation, provided the manufacturer or importer has documentary evidence of this.

Phase-in substances that missed pre-registration cannot enjoy benefits of extended registration deadline and shall be registered immediately. However, first-time exporters/producers/importers who first began manufacturing or placing phase-in substances on the European market in excess of 1t/year after 1 Dec 2008, still can benefit from extended REACH registration deadlines by submitting a late pre-registration to the European Chemical Agency. Non-EU companies shall appoint REACH Only Representative to do so.

Non phase-in substances("new substances not covered by the definition of a phase in substance") need to be registered immediately before being placed in the EU market.

CMRs: carcinogenic, mutagenic or toxic to reproduction

Please click here to search whether your substances have been classified as CMR substances or R50/53 substances.

REACH Registration: How to register

Registration of phase-in substances as lead registrant;
Registration of phase-in substances as a member of joint submission;
Registration of non-phase-in substances;
Registration of intermediates;

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