Page 43 - CITDBooklet

Guide on the application of REACH Regulation

As a potential registrant you will have two options
■ Do stand-alone registration all by your self
■ Submit joint registration through the SIEF (see chapter 4)

If you choose second option, you again have sub-options:
1. Participate in SIEF as an entity. Submit all data for which you are an owner (after due
payments), complete the process
2. Join a “Consortia”. Here again you have two options
1. Join “Consortia” as a member by paying fees and become ‘owner’ of data by
paying data costs.
2. Get a “Load” from the “Consortia” which allows you to complete your
registration without becoming the owner of the data

8.2 REACH Preparation

1. Make a list of products exported to EU and wherein you have decided to
proceed with the REACH process

2. If the product is a “Substance” register “as it is”
3. If the product is a “Preparation” or “Mixture” make a list of “Substances in the

preparation”.
4. These individual substances need to be registered separately.
5. Decide tonnage band for each substance based on percentage composition and

exports over last 3 years as well as potential.
6. Once a list of all substances is made, update the list with:

- CAS No

- Name of the substance ( IUPAC name, Trivial name, etc.)

- Uses / application of the substance for which it is exported

7. Appoint an “Only representative” and proceed with “Pre-registration” or
“Registration” as applicable. Inform your customers of this appointment.

8. Now undertake detailed “Substance identification” studies to know your
substance accurately. This involves analyzing the composition with the help of
chromatographic / spectroscopic data. Also decide whether your substance
is “ Mono-constituent, multi constituent, UVCB etc).

9. Make a list of all test data that you posses. This should include the name of
parameter, values, units, test method used, lab where data was generated
(In-house, ISO 17025 accredited, GLP certified etc.)

10. With the help of “OR” examine all exemptions.
11. Submit all this data to your OR and interact with him regularly till the process is

completed

Notes:

■ “Phase-in” substances can be pre-registered.
■ Non phase in substances have to be registered directly.
■ Late pre-registration is now possible only for last deadline till 31st May 2017

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