REACH requires all companies manufacturing or placing a substance on the EU market in quantities greater than 1t/year to register that substance with the European Chemicals Agency (ECHA). For legal reasons, only companies with a legal entity in Europe are allowed to submit a registration under REACH; however, non-EU companies may submit REACH registration by appointing an Only Representative to register on their behalf, in which case their importers will be regarded as downstream users and do not need to do registrations.
The Scope of REACH Registration
Substances manufactured/imported above 1t/y on its own or in preparations; (Note: some substances are exempted.)
- Substances in articles if present above 1 t/y and intended for release (for example, ink a pen);
- Monomer substances if present at a concentration above 2% in a polymer (for polymers, monomers shall be registered);
- Intermediates - reduced requirements and lower costs;
- Substances subject to Product and Process Oriented Research and Development (PPORD) exempted from registration for 5 (+ 5) years; However, PPORD notification needs to be submitted.
Who Shall Submit REACH Registrations
- Manufacturers/Importers in EU;
- REACH only representative appointed by non-EU manufacturers;
The Deadline of REACH Registration
Substances can be categorized into two groups under REACH: phase-in substances and non phase-in substances. Each group has different REACH registration deadline.
Phase-in substances (existing substances) enjoy benefits of extended registration deadlines if pre-registered before Dec 2008. The principle is that the higher the tonnage, the earlier the registration deadline. Substances classified as CMR1/2 or R50/53(100t/y+) need to be registered before 30 Nov 2010 (see next diagram).
Non phase-in substances (new substances not covered by the definition of a phase in substance) need to be registered immediately before being placed in the EU market.
Definition of Phase-in Substance
A substance which meets at least one of the following criteria:
- It is listed in the European Inventory of Existing Commercial Chemical Substances (EINECS).
- It was manufactured in the Community, or in the countries accepted to the European Union on 1 January 1995 or on 1 May 2004, but not placed on the market by the manufacturer or importer, at least once in the 15 years before the entry into force of this Regulation, provided the manufacturer or importer has documentary evidence of this.
- It was placed on the market in the Community, or in the countries accepted to the European Union on 1 January 1995 or on 1 May 2004, before entry into force of this Regulation by the manufacturer or importer and was considered as having been notified in accordance with the first indent of Article 8(1) of Directive 67/548/EEC but does not meet the definition of a polymer as set out in this Regulation, provided the manufacturer or importer has documentary evidence of this.
Phase-in substances that missed pre-registration cannot enjoy benefits of extended registration deadline and shall be registered immediately. Non-EU companies shall appoint a REACH Only Representative to do so.
Quick Guidance to REACH Registration
- If you have appointed OR but wish to transfer OR to CIRS to help you complete registration at lower cost, please click here;
- If one substance is of strategic importance to you and no lead registrant or consortium is in place, please click here - lead registrant;
- If your substance is used as intermediate by your customers, please click here;
- If your substance is a polymer, please click here;
- If your substance is used for the purpose of product development and research (PPORD), please click here;
Note 1: Intermediate registration and PPORD notification are much cheaper than REACH registration. If your substance meets the definitions of intermediate or PPORD, intermediate registration and PPORD notification are strongly recommended.
Note 2: If you place a chemical on EU market, you shall also comply with CLP regulation.
Chemical Inspection and Regulation Service (CIRS) is a leading product safety and chemical management consulting firm providing valued product regulatory compliance service, tailored solutions and original information to help clients gain competitive advantage by reducing business risks associations with regulatory affairs and removing barriers to entry. CIRS has provided cost-effective regulatory support to over 3,000 companies while doing businesses in both the EU and China. CIRS is the largest REACH only representative in the world. Since 2007, we have:
- pre-registered over 10,000 substances;
- registered over 1,000 substances;
- served as lead registrant for over 100 substances;
- prepared over 5000 REACH SDS and CLP labels to date;
- acted as only representative for over 3,000 non-EU companies;
- served clients in more than 25 countries;
CIRS is a recommended service provider by China Inspection and Quarantine Bureau, the US Mission to the EU and IDA. CIRS is also a member of Helsinki REACH Centre.
Why Choose Us
Our full-range REACH registration services will provide end-to-end solutions to REACH registration. We have helped hundreds of non-EU firms and EU companies acquire over 180 REACH registration numbers up to date. The reasons to choose us include:
- Extensive substance specific registration experience;
- Broad communications with SIEF/Consortium;
- No hourly rates and hidden charges;
- Success guaranteed;
- Free regulatory updates and free consultations;