Late Pre-registration

In accordance with REACH, phase-in substances ("existing substances") enjoy benefits of varied extended registration deadlines if pre-registered before 1 Dec 2008. The principle is that the higher the tonnage is, the earlier the registration deadline is (2010, 2013 and 2018).
REACH pre-registration ended on Dec 1 2008. However, non-EU exporters/EU importers/EU manufacturers who first began manufacturing or placing phase-in substances on the European market in excess of 1t/year after 1 Dec 2008, still can benefit from extended REACH registration deadlines by submitting a late pre-registration to the European Chemical Agency. Non-EU companies shall appoint EU-based REACH Only Representative to do so.

Note: Late pre-registration is cheap and it should always be your first choice if you are first time players.

Please also note that the EU Buyers would typically insist for the REACH Compliance certificate and SSS after completing the process of LPR would be able to deliver such a certificate; SSS’s such certificate are presently being acknowledged and accepted by over 2000 EU buyers.

If you missed pre-registration and do not qualify for late pre-registration, please see our Support Services section or consult us for free advice

What is meant with extended registration deadlines?
Article 23 of the REACH Regulation provides for a scheme with staggered registration deadlines for so-called ’phase-in substances’, depending on the tonnage band and hazards of the substance. The respective deadlines to submit the registration dossier to ECHA are as follows:

  • 30 November 2010 for CMR1 ≥ 1 t/y, R 50-532 ≥ 100 t/y and other substances ≥ 1000 t/y; or
  • 31 May 2013 for other substances ≥ 100 t/y; or
  • 31 May 2018 for other substances ≥ 1 t/y;

How do I know if I qualify for a late pre-registration?
You may submit late pre-registration after 1 December 2008 if you are:

  • able to prove that you are established in the European Community and manufacturing or importing phase-in substances (on their own or in a preparation or in articles intended to be released) for the first time after 1 December 2008 in quantities of 1 tonne or more per year;
  • non-EU companies exporting phase-in substances (on their own or in a preparation or in articles intended to be released) for the first time after 1 December 2008 in quantities of 1 tonne or more per year may appoint Reach Only Representative to submit late pre-registration to relieve the obligations of EU importers under REACH.
  • If this is the case, the following deadlines apply:
  • At the latest six months after manufacturing or importing exceeds the one-tonne threshold; and at least 12 months before the relevant transitional deadline for registration.