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 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.
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.
For REACH pre-registration only a limited amount of information is required.
If the identity of the substance is uncertain, it may however require a lot work to establish the correct substances identity to the satisfaction of ECHA.
ECHA does not charge a fee for Pre-registration.
The costs for REACH pre-registration consist of:
• The cost of collecting the information.
• Where applicable: a fee for the ‘Only Representative’.