REACH Update January 2008: Pre-registration and SIEF Formation
Posted: December 31, 2007
Preparation for Pre-registration and SIEF Formation: Part 1
REACH offers extended registration deadlines for pre-registered substances. Pre-registration allows companies to continue manufacturing and importing their substances for several years until the registration deadline is reached. The pre-registration phase is from Jun. 1–Dec. 1, 2008; however, it applies only to phase-in substances that meet one of the following criteria:
- they are listed in the European Inventory of Existing Commercial Chemical Substances (EINECS);
- they were manufactured but not placed on the market at least once within 15 years before REACH entered into force;
- they are no longer polymers according to Article 3(20)REACH.
The pre-registration can be submitted by the manufacturer or the importer of a substance and by the “only” representative of a noncommunity manufacturer. Third party representatives appointed by an EU-manufacturer or importer cannot submit the pre-registration, the manufacturer or importer is responsible for this and must indicate the contact detail of the third party representative in the pre-registration file.
The necessary information for pre-registration includes: substance name including the CAS and EINECS numbers or other identity codes; the name and address of the company and contact person; the envisaged registration deadline depending on tonnage band and nature of the substance; names of other substances that are relevant for quantitative structure-activity relationships (QSARS) or read across approaches.
After the pre-registration phase, the European Chemicals Agency will publish the list of pre-registered substances (in January 2009). This publication does not include the names of pre-registering companies. Companies will know the identity of other pre-registrants of the same substance through the IT system that will be provided for pre-registration.