REACH Registration

Registration is the process by which manufacturers and importers submit to ECHA a dossier which details the phys-chemical and toxicological properties of their substance and provides guidance on hazard, risk and safe use.

A range of dossier submissions services are available at ELC Group

  • Substances manufactured/imported above 1 tonnes per annum on its own or in preparations.
  • Substances in articles intended for release above 1 tonne per annum
  • Monomer substance that make up the polymer's "chemically-bound structure" at concentration >2 wt% and the total quantity of such monomer substance or other substance(s) makes up at least 1 tonne per year.
  • Intermediate: On-site isolated intermediate and transported isolated intermediate with reduced registration requirement.

Phase In & Non Phase In Substance

"Phase In" Substance are chemical substances which will be ‘phased in’ to the REACH regulation.

They fall into one of three categories:

  • Current EINECS Substances
  • Substances manufactured in the EU, but not placed on the market before REACH came into effect (i.e. 01 June 2007) NLP (no longer polymer) Substances
  • Again, all of these substances must be pre-registered to enjoy the phase-in period benefit prior to full registration requirements – if not pre-registered, full registration will be required BEFORE substance is manufactured and/or imported into the EU.

There are two types of Non-Phase In substances with different registration requirements.

So-called ELINCS substances

  • These are substances which were notified under the previous scheme from 1981 onwards with a toxicity data set based on volume
  • The substances are considered to be already registered under REACH
  • The ELINCS registration number will be converted to a REACH registration number by the end of 2008

Any ‘New Chemical’ invented after 01 June 2007 and manufactured/imported at > 1 T/Annum per legal entity must be registered (not pre-registered) under REACH immediately.

During lifecycle of a REACH project there is an option to take a role either of Lead Registrant or Joint Registrant. Depending on substance vital importance ELC Group experts can analyze your business needs and advice you on most viable option between two.