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REACH
Pre-Registration has Ended
Regulation (EC) 1907/2006
ECHA Pre-registration Brochure
Beginning June 1, 2008, substances must be registered with the European
Chemicals Agency (ECHA) before they can be imported, sold or used in the
European Union. This is known as the "no data, no market" principle.
However, phase-in substances that were pre-registered between June 1 and
December 1, 2008 qualify for staggered registration dates over
the next decade. This means that you may continue to import, sell and/or use
these substances without submitting a registration.
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The
registration deadline for pre-registered
phase-in substances is determined by your quantity of the
substance and its danger to humans or the environment: |
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December 1, 2010: |
1 tonne or more
and carcinogenic,
mutagenic or toxic to reproduction (CMT)
100 tonnes or more
and very toxic to
aquatic organisms (R50/53)
1,000 tonnes or more |
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June 1, 2013: |
100 tonnes or more |
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June 1, 2018: |
1 tonne or more |
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Phase-in substances are one of
the following: |
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Listed in the
EINECS (European inventory of
existing commercial chemical substances), i.e. an "existing"
substance under
Directive
67/548/EEC placed on the market prior to September 18, 1981 |
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Manufactured
in the EU sometime between June 1992 and May 2007 but never placed
on the market |
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'No
longer polymers', i.e. substances defined as a polymer
under Directive 67/548/EEC but not under Directive
92/32/EEC (its seventh amendment) |
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Pre-registration was free and required
submitting the following information to ECHA: |
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Name of the
substance, EINECS and CAS number |
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Name and contact
information for your company |
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Your anticipated
tonnage to be registered (and registration date) |
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Name of any
substance(s) that might facilitate the risk assessment of the
substance, if applicable |
Importers based outside
the EU (called 'exporters' by ECHA) may not
pre-register their substances directly. They must rely on the
company importing their substance or engage the services of an Only
Representative.
There are a number of
complex, strategic issues that companies based outside the EU must consider
in formulating their response to REACH. If you and your company need
assistance in preparing for REACH, please
email
or call us at 972-679-8996.
This summary of REACH Pre-Registration
is designed to provide you with an accurate, easy-to-understand overview of
the topic
and
does not
constitute legal advice. The actual standard in the original language
should be reviewed and used for all business, legal, and product
compliance purposes.
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2009 -- All Rights Reserved
RSJ
Technical Consulting
PO Box 867705, Plano, Texas 75086
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