In accordance with REACH, phase-in substances("existing substances") enjoy benefits of varied extended registration deadlines if pre-registered before 1 Dec 2008. The principle is that the higher the tonnage is, the earlier the registration deadline is (2010, 2013 and 2018).
REACH pre-registration ended on Dec 1 2008. However, non-EU exporters/EU importers/EU manufacturers 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 EU-based REACH Only Representative to do so.
Definition of 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.
New substances not covered by the definition of a phase in substance are called non phase-in substances and need to be registered immediately before being placed in the EU market.
What is meant with extended registration deadlines?
Article 23 of the REACH Regulation provides for a scheme with staggered registration deadlines for so-called ’phase-in substances’, depending on the tonnage band and hazards of the substance. The respective deadlines to submit the registration dossier to ECHA are as follows:
30 November 2010 for CMR1 ≥ 1 t/y, R 50-532 ≥ 100 t/y and other substances ≥ 1000 t/y; or
31 May 2013 for other substances ≥ 100 t/y; or
31 May 2018 for other substances ≥ 1 t/y;
How do I know if I qualify for a late pre-registration?
You may submit late pre-registration after 1 December 2008 if you are:
able to prove that you are established in the European Community and manufacturing or importing phase-in substances (on their own or in a preparation or in articles intended to be released) for the first time after 1 December 2008 in quantities of 1 tonne or more per year;
non-EU companies exporting phase-in substances (on their own or in a preparation or in articles intended to be released) for the first time after 1 December 2008 in quantities of 1 tonne or more per year may appoint REACH Only Representative to submit late pre-registration to relieve the obligations of EU importers under REACH.
If this is the case, the following deadlines apply:
At the latest six months after manufacturing or importing exceeds the one-tonne
at least 12 months before the relevant transitional deadline for registration.
If you missed pre-registration and do not qualify for late pre-registration, please see our registration service or consult us for free advice.
Our Late Pre-registration Services
Late pre-registration is cheap and easy and it is strongly recommended for first-time exporters/importers. Late pre-registration also gives you more time to think about whether to do registration or not. Late pre-registration can be done in 1~2 days.
If you are interested in our services, please don't hesitate to contact Mr. Yunbo Shi at yunbo.shi at cirs.ie. We will be glad to provide free consultations.
Acting as Only Representative and taking full obligations of importers under REACH;
Creation and submission of pre-registration data to ECHA;
Communication with importers/downstream users;
Representation in Substance Information Exchange Forum(SIEF) after pre-registration;
Please request "Application Form for Late Pre-registration"