REACH Pre-Registration

REACH Pre-Registration

REACH Pre-registration distinguishes between existing and new substances. It ensures that a substance is regarded as ‘existing’.   Under REACH, new substances cannot be pre-registered, but must be registered immediately.

Pre-Registration at a glance

REACH Pre-registration is needed for existing substances.   Pre-registration distinguishes between ‘phase-in (i.e. existing) substances’ and new substances.   Without REACH pre-registration, the competent authorities may demand immediate registration; even for an existing substance. If a chemical is not pre-registered, it cannot be marketed safely.
Even if there is no intention to actually register a substance (as may be the case for importers of mixtures) it should still be pre-registered. This is necessary to avoid being obliged to register at a very inconvenient moment.   REACH Pre-Registration of a substance does not imply that the substances must also be registered.

REACH Pre-Registration Deadlines

The REACH pre-registration deadline was 30 November 2008.   Late REACH pre-registration is possible for first time manufacturers and importers and newly appointed Only Representatives.
REACH Pre-registration is not possible in the last twelve months before the applicable registration deadline.   Forgot to pre-register? Contact us; we will find a solution.

Who must Pre-Register?

REACH Pre-registration must be done by every legal entity that could in the future be required to register:   • EU based manufacturers of substances.   • Only Representatives of non-EU manufacturers of substances.   • Only Representatives of non-EU formulators (producers of mixtures)   • EU based importers of substances (unless an Only Representative has been appointed).   • EU based importers of mixtures (unless an Only Representative has been appointed).
Even if REACH Registration will later be done by a supplier, these legal entities must still Pre-register. Otherwise they will not be safe until the registration has actually taken place.   If a chemical company has several production plants in Europe, each of these must pre-register the phase-in substances that they produce.   If Non-EU producer has several importers in the EU, every separate importer must pre-register, unless an ‘Only Representative’ has been appointed.   REACH Pre-registration is also possible for those who do not yet manufacture or import substance. The ‘intention’ to do so is enough. Pre-registration does not oblige you to actually register.

Substances below 1 tonne per year

The REACH lower threshold is one tonne (1.000 kg) per year.   If a substance is marketed in a lower quantity, pre-registration is not required.
This may be especially relevant for low concentration substances in imported mixtures.   It is however wise to take some margin of safety.

Forming of SIEFs

REACH Pre-registration brings all potential registrants of the same substance together in a virtual network called SIEF (Substance Information Exchange Forum).  
SIEF members are expected to exchange information. They are also expected to avoid animal testing, as much as possible.

Costs of REACH Pre-registration

For a REACH pre-registration only a limited amount of information is required: the chemical name and the cas or ec number.  
ECHA does not charge a fee for Pre-registration.   The costs for REACH pre-registration is included in the Sitmae Only Representative fee.        


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