REACH Registration & Pre-registration
REACH Registration & Pre-registration
Sitmae does REACH Registrations and REACH Pre-registrations, for both Non-European and European customers. For Non-European customers this is part of our work as their REACH Only Representative. To European Importers and manufacturers of chemical products we provide this REACH service ‘stand alone’. Sitmae REACH Services has pre-registered more than six hundred different substances and submitted more than fifty successful registrations.
Deadline passed? Late pre-registrations and late registrations are often possible. Tell us the details and we will find a solution! • REACH Pre-registration • REACH Registration • Late pre-registration • Late registration • Ethanol is special
Pre-registration is necessary. Without it, the registration deadlines do not apply and immediate registration becomes necessary. For non-European customers, pre-registration is part of our Only Representative service. We also pre-register substances as a service for European companies that import or manufacture chemicals. Our pre-registration service consists of: • We check substances for REACH exemptions. • We check substances for the possible need of early registration (Carcinogen, Mutagens, Reprotoxins, or Classified R50/53).
• We provide assistance in finding the correct Chemical names, CAS and EC numbers. • We provide assistance in finding the main monomers in the polymers. (The monomers must be pre-registered. Polymer suppliers are not always forthcoming with information). • We give advice on issues like: tonnage bands, substances of variable composition, substances from natural origin, etc. For more detail on this subject see our dedicated web page ‘Pre-Registration’.
REACH Registration is necessary by certain deadlines, depending on the annual volume marketed. We register substances for both our non-European and European customers. Most registrations are ‘joint submissions’. A REACH consortium of active companies prepares the REACH registration dossier. Other registrants may join their registration. They must buy a ‘Letter of Access’ to the joint registration. For joint submissions, our REACH registration service consists of: • We determine by which deadline the substance must be registered under REACH. • We find the right REACH consortium for your substance and determine the fee for the ‘Letter of Access’. • We provide the customer with a short list of data that must be provided. If necessary we assist in collecting this data.
• We check together with our customer if the consortium’s substance ID exactly covers the customers’ substance. • We acquire the ‘Letter of Access’ from the REACH Consortium. • We complete the IUICLID registration dossier with the customer’s data. • We determine with the customer if an SME discount can be obtained for the ECHA registration fee. (SME: Small and medium Sized Enterprise). • We collect and record the necessary SME-proof from the customer. • We submit the registration dossier to ECHA (European Chemicals Agency). • We ensure payment of the registration fee to ECHA (European Chemicals Agency). Sitmae is also capable of handling more complex REACH registrations. See our section on REACH consultancy. For more detail on this subject see our dedicated web page ‘Registration’.
The deadline for REACH pre-registration was 1 December 2008. Late REACH pre-registrations are possible upon ‘first time manufacture’, ‘first time import’ and when an Only Representative is newly appointed. No pre-registration is however possible in the last twelve months before the applicable REACH registration deadline. In the case of a ‘forgotten’ pre-registration, we are often able to solve the issue, in spite of the limitations.
The late REACH pre-registration service comprises: • Study of the individual case. • Proposal for the solution. • Complete pre-registration service (See the section on ‘Pre-registration’)
When the REACH registration deadline has passed, a substance can officially not be marketed before the registration has been submitted. In case of a ‘forgotten’ REACH registration, we may be able to solve the issue. This however very much depends on the individual case.
The late REACH registration service comprises: • Study of the individual case. • Proposal for the solution. • Complete registration service (See the section on ‘Registration’)
Our involvement Sitmae REACH Services is heavily involved in the registration of Ethanol. More than a dozen non-EU manufacturers of Ethanol have appointed Sitmae as their ‘Only Representative’. Also a number of European ethanol manufacturers and importers use our services. We have done more than ten successful Ethanol registrations. Mr.Verspoor, our Senior Consultant, was a respected member of the Steering Group of the Ethanol Consortium and Mr. Jeff Kelsey, our senior toxicologist, is the main author of the registration dossier.
Ethanol consortium A large Ethanol Consortium has been set up in the form of an association: EtOH-REACH. All manufacturers (both EU and non-EU), all importers, all non-EU formulators and many other interested parties can join. More than four hundred European manufacturing sites, importers, non-EU manufacturers and non EU formulators have already registered ethanol.