Page 21 - CITDBooklet

Guide on the application of REACH Regulation

■ Inform all importers within the same supply chain of the appointment of OR
■ An OR can represent several non-EU manufacturers of substances.
■ What about quantities below one tonne/year?
■ M/I of phase in substances less than 1 tonne/year need not pre-register.
■ They can pre-register if they have intention of crossing the 1 tonne/year threshold.
■ When the thresh hold is exceeded relevant information has to be provided to ECHA

within 6 months from date of exceeding the threshold provided this is at least 1 year
before relevant registration deadline.
■ What is the period for pre-registration?
■ 1st June 2008 to 1st December 2008 (both inclusive).
■ What about First time M/I after 1st Dec 2008?
■ 1st time of M/I after 1st Dec 2008 can pre-register within six months of exceeding the
threshold and at least 1 year before the relevant deadline.
■ Thus before:
■ 30.11.2009 or
■ 31st May 2012 or
■ 31st May 2017.
■ What if pre-registration is missed?
■ Needs to suspend M/I of concerned substances.
■ Needs to register these substances at the earliest.
■ Enquire with ECHA if the substances(s) are already registered.
■ All M/I/use of such substances between period of 1st June 2008 and date of suspension
of activities may be subject to penalties.

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