Pre-registration

The pre-registration phase of the REACH Regulation ended on 1 December 2008. Pre-registration was required for all "phase-in substances" manufactured or imported in quantities reaching 1 t or more per year.

As of 1 January 2009, the pre-registration data are published by the Agency. This enables relevant parties to join the Substance Information Exchange Forum (SIEF).

Manufacturers/importers who

  • manufacture or import over 1 t p.a. of a phase-in substance, or
  • who use a phase-in substance in the manufacture of articles, or
  • who import a product containing a phase-in substance subject to registration

for the first time after 1 December 2008 must then pre-register the substance within six months of first manufacture/first import or first use of the substance in quantities exceeding 1 t p.a. and at least 12 months prior to expiry of the relevant transitional periods.

Phase-in substances are, in simple terms, "legacy substances". As defined by the REACH Regulation, phase-in substances must satisfy at least one of the following criteria (from the Baden-Württemberg Reach Network):

  • The substance is listed in the European Inventory of Existing Commercial Chemical Substances (EINECS). EINECS is the inventory of substances which were on the market prior to 1981; it contains over 100,000 legacy substances.
  • The substance was manufactured in the EU but was not placed on the market by the manufacturer or importer during the 15 years prior to entry into force of the REACH Regulation (for example: substances produced for internal company use).
  • The substance was classified as a polymer up to the beginning of the 1990s (entry into force of the 7thamending directive of Directive 67/548/EEC) and was considered registered, but does not satisfy the definition of a polymer under the REACH Regulation. These substances are termed "no-longer polymers".

Substances which do not satisfy any of the stated criteria are either "notified substances" which are regarded as being registered under Article 24, or "non-phase-in substances".