Page 18 - CITDBooklet

Guide on the application of REACH Regulation

Thus potential registrants need to take following steps:
1. Study the chemistries to see if there are repetitive monomeric units in their substances.
2. Undertake GPC (gel permeation chromatography) to study the molecular weight
distribution.
3. See if their products meet the definition of Polymers.
4. See if it is included in NLP list.
5. Claim exemptions under REACH if polymeric.
6. Start pre-registration / registration process if NLP
7. In case of exempted polymers ensure that the monomers and other substances are
pre-registered/registered by the upstream manufacturer.

2.5 PRE-REGISTRATION:

2.5.1 Pre-registration process
■ Pre-registration of substances was possible from 1st June 2008 to 30th Nov 2008 (6
months).
■ Pre-registration possible only for “Phase-in Substances” (see explanation below).
■ Late pre-registration possible 12 months before deadline for first time manufacture/
import ((30.Nov 2010, 31st May 2013 or 31st May 2018)).
■ Pre-registration gives you additional time to organize, collect and assess available
data, sharing of existing data and collective generation of missing information.
■ Ensures that there will be no interruptions in the supply to downstream users of your
substances.
■ Provides basis to make existing information on substances e.g.
o Non-testing information
o Substance to substance read across data from testing accessible to those who need
the information for registration.
■ Allows you to continue manufacture or import of phase-in substances until relevant
registration deadline (30.Nov 2010, 31st May 2013 or 31st May 2018)
■ If you do not pre-register, than you cannot manufacture or import material from 1st
Dec 2008 onwards until the registration is completed
■ If you are a company consisting of several legal entities, manufacturing in EU or
importing the same substance, each legal entity has to pre-register separately
■ If you do not wish to make contact details available to other registrants than you
should appoint Third Party Representative (TPR) who then pre-registers
■ Limited data requirements for pre-registration e.g.:
■ Identity of manufacturer / importer
■ Identity of substance
■ Envisaged deadline for the registration + tonnage band
■ Proposals for grouping of substances (similar substances)
■ European Chemical Agency ECHA has published a list of all pre-registered substances
one month after the deadline of November 2008.

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