Interviews
Answers to FAQs on pre-registration of REACH
25 Nov '08
4 min read
4. Do I have to pre-register a substance previously notified in accordance with Directive 67/548/EEC by other manufacturers?
A notification under Directive 67/548/EC is nominal so that only the notifier benefits from being considered registered. Any other parties manufacturing or importing the substance but who have not notified it, do have (pre)registration obligations unless they may benefit from one of the exemptions in the REACH Regulation.
Click here for more information on notified substances in section 6.3.6 of the Frequently Asked Questions on REACH:
5.One of our pre-registration was submitted, but it is not on ECHA's intermediate list of pre-registered substances. Why?
We would like to clarify that the published list is only an intermediate list of pre-registered chemical substances. ECHA decided to release this intermediate list as an additional service to allow Downstream Users of chemicals a possibility to determine whether substances of their interest are already pre-registered.
As required by Article 28 of the REACH Regulation the final list will be published by 01 January 2009. The list will comprise all phase-in substances pre-registered within the time period starting on 1 June 2008 and 01 December 2008.
Your substances might be missing from the intermediate list of pre-registered substances as some submissions required further examination by the Agency and potentially, clarification by companies.
6.Do I have to pre-register a substance that has already been pre-registered by another party?
In accordance with Art 6(1) of REACH, a registration shall be submitted to the Agency by all manufacturers or importers established in the European Community for all substances they manufacture or import in quantities of 1 tonne or more per year (unless they are explicitly exempted from the scope of registration by other provisions of the Regulation).
7.What documentation will I need to provide to the REACH Enforcement Authorities to prove my manufacturing/importation tonnage?
In accordance with Article 125 and Article 126 of the REACH Regulation the enforcement of the REACH Regulation lies in the remit of the Member States. Therefore we would suggest that you contact the relevant national authorities of your EU distributors. Click here.
A notification under Directive 67/548/EC is nominal so that only the notifier benefits from being considered registered. Any other parties manufacturing or importing the substance but who have not notified it, do have (pre)registration obligations unless they may benefit from one of the exemptions in the REACH Regulation.
Click here for more information on notified substances in section 6.3.6 of the Frequently Asked Questions on REACH:
5.One of our pre-registration was submitted, but it is not on ECHA's intermediate list of pre-registered substances. Why?
We would like to clarify that the published list is only an intermediate list of pre-registered chemical substances. ECHA decided to release this intermediate list as an additional service to allow Downstream Users of chemicals a possibility to determine whether substances of their interest are already pre-registered.
As required by Article 28 of the REACH Regulation the final list will be published by 01 January 2009. The list will comprise all phase-in substances pre-registered within the time period starting on 1 June 2008 and 01 December 2008.
Your substances might be missing from the intermediate list of pre-registered substances as some submissions required further examination by the Agency and potentially, clarification by companies.
6.Do I have to pre-register a substance that has already been pre-registered by another party?
In accordance with Art 6(1) of REACH, a registration shall be submitted to the Agency by all manufacturers or importers established in the European Community for all substances they manufacture or import in quantities of 1 tonne or more per year (unless they are explicitly exempted from the scope of registration by other provisions of the Regulation).
7.What documentation will I need to provide to the REACH Enforcement Authorities to prove my manufacturing/importation tonnage?
In accordance with Article 125 and Article 126 of the REACH Regulation the enforcement of the REACH Regulation lies in the remit of the Member States. Therefore we would suggest that you contact the relevant national authorities of your EU distributors. Click here.
European Chemical Agency
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