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 and 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.