REACH-SERV arrow Industry news arrow Downstream Users Q&A on pre-registration
Downstream Users Q&A on pre-registration Print

Do I need to pre-register my substance? 

No, not unless you are an importer. 

You may need to pre-register if you import your substance and your supplier has not appointed an Only Representative to act on their behalf.  In this case you are an Importer under REACH and not a Downstream User.  

My supplier has not pre-registered, what do I do? 

If your supplier does not pre-register your substance by 1 December 2008:

  • you must find an alternative supplier;
  • you may use any existing stocks you hold, but it is illegal for your supplier to supply any further material.  

My substance has not been pre-registered, what do I do?

 From the beginning of 2009 you will be able to find out if your substance has been pre-registered by referring to the ‘List of pre-registered substances’ held on ECHA’s website at . If your substance has not been pre-registered you should contact ECHA.  They will want to know:

  • who you are;
  • what your substance is;
  • your current supplier. 

In return they will tell you of any manufacturer or importer who contacts them regarding your substance in order to help you find a new supplier. 

Even if your substance appears on this list it does not guarantee that your supplier has pre-registered.  Details of potential registrants will not be shown and it is up to you to satisfy yourself that your supplier has pre-registered.  

My new supplier is based outside the EU and does not have an Only Representative:

a) do I need to register?

Yes, if your new supplier is based outside the EU and has not appointed an Only Representative you are now an importer under REACH and you will have to register your substance. You are only responsible for the tonnage that you import.

If you take on Only Representative status for your supplier, you will be responsible for registering the total tonnage that they export to the EU.

b) do I qualify for late pre-registration?

If you become an importer or an Only Representative for the first time after 1 December 2008, you will be able to pre-register late providing you pre-register:

  • within 6 months of starting to import above 1 tonne per year, and
  • at least 12 months before the deadline for the appropriate annual tonnage band.
Last Updated ( Wednesday, 26 August 2009 )
© 2017 REACH Regulation: Registration, Evaluation, Authorization and Restriction of Chemicals: REACH Legislation