To benefit from the 31 May 2018 registration deadline for low volume, existing substances, you need to have pre-registered them. You can still do so if you have recently entered the European market. The last chance is on 31 May 2017. If you do not pre-register by that date, you will need to register your substance before you can manufacture or import it.
Helsinki, 5 April 2017 – If you have recently started to manufacture or import a non-CMR phase-in substance in amounts of 1 to 100 tonnes a year, you should pre-register it within six months after starting the activity. The last possibility is on 31 May 2017. Pre-registration enables you to continue supplying your low-volume chemicals legally on the EU/EEA market until the last REACH registration deadline on 31 May 2018.
If you do not have a valid pre-registration or registration for your substance after 31 May 2017, you will need to submit an inquiry to ECHA and register your substance before you can manufacture or import it. Preparing an inquiry with IUCLID will take you more time than pre-registering through REACH-IT, will need to contain more information, and will take more time for ECHA to process. You need to take this into account when planning your access to market to avoid delays.
If you manufacture or import your substance for research and development (PPORD), and only make it available to a limited group of customers, you may benefit from a specific PPORD exemption. In this case, you do not need to register or pre-register your substance.
Chementors can assist you with the pre-registration but you need to act now!