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REACH Registration Timeline

1 June 2007 6 months
from 1st June 2008 to 1st December 2008
3.5 years
December 2010
6 years
June 2013
11 years
June 2018
REACH comes into force 1 June 2007

>1 tonne


Late pre-registration is still possible 


1,000 tonnes/year
+ CMRs (Cat 1&2) >
1 tonne/year
+ very toxic (R50/53) >
100 tonnes/year


100-1,000 tonnes/year


1-10 tonnes/year
10-100 tonnes/year


REACH Update

  • All companies responsible for introducing a phase-in substance with a minimum volume of 1 tonne/year into the EU, either by manufacture or import, must have pre-registered or registered that substance.

  • All companies manufacturing/importing a substance identified in any of the following categories must have registered the substance with ECHA -

         a.    where the volume is 100 tonnes/year or greater
         b.    it is a recognised R50/53 toxin of >100 tonnes/year
         c.    an identified CMR (cat. 1 & 2) of a least 1 tonne/annum

  • Companies manufacturing a substance which falls into any of the above categories (a, b or c) and which has not been registered are operating illegally and must cease activity until the situation is resolved.

  • Companies who use any substance which falls into any of the above categories (a, b or c) and is supplied from within the EU must ensure it has been registered by an upstream supplier and that the registration covers their use. In this instance the company is considered a "downstream user" and is exempt from registration.

  • Companies who import into the EU any substance which falls into any of the above categories (a, b or c) must ensure it has been registered by an Only Representative (OR) acting on behalf of the non-EU supplier if they wish to claim "downstream user" status and be exempt from the duty of registration. To be considered a downstream user the importer must make themselves known to the OR and should obtain documentary evidence that the substance and the tonnage they imported are recognised under the terms of the registration.

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