Late pre-registration


A company that failed to preregister a phase-in substance by 1 December 2008 may neither import nor manufacture it until it has fully registered the substance with the European Chemicals Agency (ECHA). While a downstream user who is not manufacturing or importing the substance is not required by the REACH Regulation to pre-register a phase-in substance, he cannot place the not preregistered substance on the market until it is registered by the supplier. A downstream user of a substance that does not appear on the ECHA list of pre-registered substances, may in this respect notify ECHA of his interest in the substance. In theory ECHA will then provide contact details of the downstream user to a potential registrant.



Potential registrants who, for the first time after 1 December 2008, manufacture or import a phase-in substance in quantities of one tonne per year or more can still submit certain information to ECHA (late pre-registration) and benefit from the extended deadlines. Producers and importers of articles with an intended release of a substance can also submit a late pre-registration. Late pre-registrations have to be submitted within six months after the manufacturing or importing of the substance that exceeds the one-tonne threshold and no later than twelve months before the relevant registration deadline. Therefore, the late pre-registration period ends on 31 May 2017 for substances to be registered by 31 May 2018.



Late pre-registration is only obligatory if companies want to benefit from the extended registration deadlines. Companies can also decide to register their phase-in substances immediately, but in this case it is necessary to first submit an inquiry.



More information on: ECHA’s Q&A on pre-registrations:




Latest update: 27 December 2017