The Importance of Pre-Registration in 2008

Pre-registration is effectively a temporary exemption to full registration and allows time for the SIEF to be formed and cooperate in its data sharing aims during the phase-in periods. There will be one SIEF for each pre-registered substance.

The phase-in timetable for substance registration (December 2010, June 2013 and June 2018 depending on registrant tonnage) only applies to existing substances that have been pre-registered with the ECHA. Without pre-registration you will need to suspend your EU activities in that substance from June 1 2008 until a full registration dossier has been submitted to the ECHA. As an EU legal entity without a substance pre-registration, you may be considered as marketing that substance illegally if you continue to manufacture or import after 1 December 2008.

Pre-registration is a relatively simple process and, at the time of writing, is free-of-charge.

What information is required in Pre-Registration?
The requirements of pre-registration are set out in Article 28 of the REACH text and ask for the following information to be submitted:

  • The name of the substance plus its EINECS and CAS numbers
  • The name and address of the manufacturer or importer or person representing them.
  • The envisaged deadline for the registration and the tonnage band;
  • Any information that already exists regarding computer predictions of the toxicity of that substance (QSARs) or toxicological properties that are predicted by comparing the substance to ones with a similar chemical structure (read-across).

How do I Pre-Register ?
Pre-registration will take place on-line using the IUCLID5 software that was issued by the Commission in June 2007. This can be downloaded from the ECHA website.