The European Commission clarified some of the dispositions that applied to phase-in substances. These dispositions will continue to apply until 31st December 2019, which means that companies have until this date to benefit from the advantages of the transitional regime.


Limit is fixed for 31st December for phase-in substances

The European Commission published in October an implementing regulation regarding REACH phase-in substances. This regulation specifies that some dispositions of the transitional regime for chemical substances called “phase-in” will continue to apply until the end of this year, on 31st December 2019.

Until then, pre-registrations will therefore remain valid as will the method for calculating tonnage bands (average on the three preceding years).

Consequences on the registration process

Consequently, starting in 2020, pre-registrations will not be valid anymore. Companies wishing to register substances will now systematically need to go through an inquiry even if they did proceed to a pre-registration before. The method for calculating tonnage bands will now need to be based on the calendar year.

Additionally, this implementing regulation clarifies the future requirements in terms of data-sharing practices and in case of disputes.

If you have pending pre-registrations you should consider using them before it is too late and proceed to the registrations before they are no longer valid. The inquiry is an additional step as well as additional costs and thus requires more data than a pre-registration.

Wish to know more more on REACH phase-in substances?

For more information, do not hesitate to contact Renaud Germain-Thomas or one of our experts by phone: +33 1 83 64 20 54 for Europe or +1 (778) 234 1607 for North America or to contact them using our contact form, selecting "REACH Registration" as the purpose of your inquiry.


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