What has to be registered and who has to register?
All substances, either on their own or in preparations, manufactured or imported in quantities ≥ 1 tonne/a, , have to be registered. → article 6
Example:
The stabilisers manufactured by The Chemson Group under the trade names of “Naftomix” and “Naftosafe” are preparations (blend of two or more substances) and are not subject to registration, however the single components within these preparations have to be registered .
The manufacturer or importer (“the registrant”) is responsible for the registration which has to include a complete technical dossier as specified → in article 10.
The technical dossier must also include information on the use of a substance, which is an important element of the registration. The downstream user has to provide specific data on the use of a substance for inclusion in this dossier. Based on this and other data the Chemical Safety Report (CSR) for the substance will be prepared by the registrant.
What are the registration deadlines?
To benefit from the transitional regime mentioned in article 23, the so called “phase-in-substances” have to be pre-registered between 1 June 2008 and 1 December 2008. → article 28
Phase-in-substances are primarily the existing chemical substances listed in EINECS (European Inventory of Existing Chemical Substances) → article 3
The time periods for registration → article 23 are:
until 1 December 2010: | - phase-in-substances ≥ 1,000 tonnes/a - phase-in-substances classified as “CMR” (carcinogenic/mutagenic/reprotoxic) ≥ 1 tonne/a - phase-in-substances classified as dangerous for the environment (R50/53) ≥ 100 tonne/a | until 1 June 2013: | - phase-in-substances ≥ 100 tonnes/a | until 1 June 2018: | - phase-in-substances ≥ 1 tonne/a |
Are there exemptions for registration?
Yes, you will find this information in → article 2, → annex IV and annex V of the regulation. Amendments of annex IV and V of the REACH regulation have been published on 9 October 2008 in the Official Journal of the EU. Commission regulation (EC) No 987/2008 of October 2008. In these annexes substances exempted from registration are listed.
Important note for plastic converters:
Polymers (e.g. PVC) are exempted from registration, but the corresponding monomer (e.g. vinyl chloride) has to be registered.
Furthermore please note that under certain circumstances, registration and/or notification of substances within finished articles is also required. → See article 7!
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