Changes brought by the draft regulation
End of pre-Registration validity
According to a draft regulation regarding phase-in substances, pre-Registrations, done before May 2017, should cease to be valid on 31st December 2019.
Consequently, from this date on, companies wishing to pre-Register their substances will have to go through an inquiry application beforehand.
Other measures
Other measures are mentioned in this draft. Starting in 2020, companies will no longer be able to determine the quantities to be registered by proceeding to a three-year average. They will now need to use the quantities placed on the market on the preceding calendar year.
Additionally, even though SIEFs (Substance Information Exchange Forums) were formally ended, data-sharing requirements are still encouraged, as are similar informal communication platforms.
How can you use your pre-Registration?
To avoid “losing” your pre-registration and therefore having to go through the process of applying for an inquiry, EcoMundo recommends you register your substance before December 2019. The inquiry application requires providing more data than for the pre-registration. It therefore represents an additional step and additional costs for companies.
EcoMundo can guide through the registration process of your substance(s), in order not to lose the pre-registration you already have. Our experts put their knowledge and experience at your disposal whether you need an OR (Only Representative) or simply a consulting team.
Reminder on pre-Registrations
The pre-registration system was implemented for the first time between June and December 2008, so that manufacturers and importers could benefit from grace periodsbefore they would need to pre-register their substances. The aim of the procedure was to facilitate the process to become compliant, but also to avoid an overloading of administrative processes by spreading them out over time.
A second pre-registration campaign, known as late pre-registration, was open until 31st May 2017. These two pre-registration campaigns, designed for phase-in substances, allowed companies to benefit from the last deadline for registration between 1 and 10 tonnes per year on 31st May 2018.
Wish to know more on REACH Registration?
For more information, do not hesitate to contact our expert Renaud Germain-Thomas by phone: +33 1 83 64 20 54 for Europe or +1 (778) 234 1607 for North America or even by mail at contact@ecomundo.eu.
