Late Pre-registration

Potential registrants of phase-in substances who manufacture or import their substance in quantities of 1 tonne or more per year for the first time after 1 December 2008 can submit a late pre-registration to ECHA provided the following conditions are met:

  • No more than 6 months have elapsed since manufacturing or importing a substance above the 1 tonne threshold per year
  • At least 12 months remain before the relevant deadline for registration.

This will enable companies to take advantage of the extended deadlines for registration applicable to phase-in substances.

Late pre-registration does NOT apply to companies that failed to meet the pre-registration deadline. These companies cannot continue producing or importing the substance until they have submitted a full registration dossier.

ReFaC can assist clients in completing the late pre-registration process in the following ways:

  • Assess substance details and tonnage information for compliance with the REACH Regulation
  • Create a REACH-IT account with ECHA on behalf of the client and submit a late pre-registration on the clients behalf
  • Compile the information available on the REACH-IT portal; providing the client with SIEF updates and pre-registration number
  • Advise on the obligations following the late pre-registration. e.g. the timescales and data requirements for the full registration dossier
  • ReFaC can also be named as a Third Party Representative to act on behalf of the client within the SIEF. Please see our Third Party Representative page for more information
  • Provide an Only Representative service for non-EU companies seeking to enter the EU market

Contact ReFaC now for more information or a quotation tailored to your needs.