Page 19 - CITDBooklet

Guide on the application of REACH Regulation

2.5.2 Phase-in Substances:
Substances fulfilling at least one of the following criteria may be considered as phase-in
substances in accordance with REACH (Article 3(20)):
■ Substances listed in the European Inventory of Existing Commercial Chemical
Substances (EINECS)
■ Substances that have been manufactured in the EU (including the countries that
joined on 1 January 2007) but have not been placed on the EU market after 1 June
1992
■ Substances that qualify as “no-longer polymer’’

2.5.3 Step-wise process for Pre-registration
■ 1st make an inventory of products exported to EU.
■ Identify whether the products you export are
■ single Substances or
■ preparations containing various Substances or
■ articles containing Substances to be released
■ Identify whether they belong to any of the following lists ( polymers, intermediates,
substances for product/process development and research, substances in exemption
annexures IV or V)
■ Collect information on name, CAS Nos., EINECS No. etc. and give correct name as
per REACH.
■ Check whether the substance is a “Phase-in substance” ( having EINECS No,
manufactured in EU but not marketed after 01.06.1992 or is a NLP)
■ Identify envisaged deadline for registration corresponding to tonnage band and C&L
■ Select and appoint an OR (Only Representative)or TPR (Third Party Representative)
■ If you are obliged to Register than you are entitled to pre-register

2.5.4 Post Pre-registration:
■ The list of all pre-registered substances has been published on the ECHA website
after 1st Jan 2009. (Including CAS / EINECS No, other identity code and first envisages
deadline for registration).
■ This list is open to all.
■ Pre-registrants will have access to information about the other registrants for the same
substance.
■ All pre-registrants for the same substance will become part of Substance Information
Exchange Forum (SIEF) and will continue to do so till 1st June 2018. (One SIEF per
substance).
■ Need to actively participate in SIEF.
■ May have financial obligations in relationship to your substances.
■ Agreement on cost sharing must be reached before disclosure of information.
■ Entire SIEF is the responsibility of the registrant industry. ECHA will play no role in this.

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