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Answers to FAQs on pre-registration of REACH
25
Nov '08
In addition to the questions highlight in the News Alert of 19 November (ECHA/PR/08/47) ECHA has identified further 7 commonly asked questions for which answers are already available on the ECHA website. During the first week, the rapid response service has answered almost 900 questions. This special service for pre-registrants will be available until 1 December.

1.Can I pre-register on paper, via e-mail or through the information request web forms on ECHA's website?
Unfortunately, the European Chemicals Agency cannot accept pre-registrations on paper, by e-mail or through the information request web forms on ECHA's website.

In accordance with Article 111 of Regulation (EC) No 1907/2006 the European Chemicals Agency specifies and makes available the formats that can be used by Member States, manufacturers, importers, distributors, or downstream users in their submissions to the Agency.

The format for the submission of pre-registrations specified by the Agency is REACH-IT. Therefore, the only channel which can be used for pre-registering a phase-in substance is the REACH – IT system. REACH-IT is a web-based application.

Click here to pre-register and to sign up to the REACH-IT portal on the ECHA website.

2.How do I pre-register a substance if I cannot find this substance in EINECS?
We advise you to first verify the phase-in status of your substance as defined in Article 3(20) of the REACH Regulation, since only phase-in substances can be pre-registered. Click here to find more information on this issue in Section 1.7 of the Guidance on registration.

In case your substance fulfils the definition of phase-in substance, you can pre-register it by using CAS number and CAS name or only its chemical name. Click here for more information available in Section 1.36 and 1.37 in the Pre-registration Q&A document.

3.I manufacture and import the same substance. I signed up in REACH-IT as a company and pre-registered the tonnage of my substance I manufacture. How can I now pre-register the same substance as importer?
If your company consists only of one legal entity you shall sign up in REACH-IT only one time and when submitting the pre-registration add up the tonnages manufactured and imported when determining the tonnage band and the registration deadline.

In case you decide not to add up the tonnage of the manufactured and imported substance, you may sign up in REACH-IT as company twice. In that case it is not possible to use the same Legal Entity Object (LEO) having the same company UUID for multiple accounts, but you may use the same company identification information (name, VAT, address, etc.).

You may consider adding a numerical or other identifier to your company name when signing up in REACH-IT, to facilitate the management of different legal entity accounts.

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