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REACH Registration FAQ

• Can a "category registration" be made, i.e. the consortium prepares a CSR for a category of substances (e.g. several compounds of the metal). The consortium members then use this single CSR which covers several compounds of the same metal to register their individual substances?
  No registration by category but by substance.
• Could a “consultant” or an “Association” take the role of Lead Registrant?
  No, the Lead Registrant must be one of the registrants. However, the official representative for the lead registrant may be a consultant if he has been mandated by the legal entity to act on its behalf.
• Do I have to register as a trader?
  Trader does not exist in REACH. If a trader is an importer, yes he has to register. If a trader is a distributor, no he has to pass the information throughout the supply chain.
• Do I have to register the substance or the use of the substance?
  The substance (mentioning the identified uses in the CSR if needed).
• Do substances that were already registered under the "existing substances" regulation have to be registered again?
  Yes. However, a notification in accordance with Directive 67/548/EEC shall be regarded as a registration and the Agency shall assign a registration number by 1 December 2008.
• Do we have to provide information on the downstream use of materials that we sell but neither produce nor import?
  Yes, the distributor is obliged to ensure a good communication throughout the entire supply chain.
• Do we have to register at the ECHA the substances that we import?
  Yes, unless the substances imported into the EU have been first exported from the EU or is below 1 tonne or is exempted from registration.
• Do “unintentional impurities” (from ores or secondary raw materials) have to be registered? What if they are CMR’s?
  No, the Classification & Labelling of the substance must be notified to the Agency as of 1 December 2010. If an impurity meets the criteria for classification and is present above a certain threshold, the substance itself shall be classified and labelled, and thus this classification and labelling shall be notified to the Agency as of 1 December 2010.
• Does registration have to take into account all tonnages placed on the market today?
  Yes, the tonnage band should be calculated as an average over the last three years. However, if in the next years, the manufacturer or importer exceed the tonnage bands (>10, >100, >1000T), then additional information would have to be submitted.
• For companies with several different legal entities, will they be charged for registering each substance in each entity?
  Yes.
• For the M/I, does pre-registration automatically mean registration? Does this mean that registration bears on the pre-registered substances, or is it possible to register as UVCB a “sum” of the pre-registered substances (which have EINECS)?
  No, there is no obligation to register a substance that has been pre-registered. There is no clear answer to the second part, although this approach is followed for preparations.
• If a substance, metal or metal compound, has already been registered at the Agency by someone else, do you still have to register it?
  Yes (except in the case of substances in articles – see art. 7)
• If I produce substances abroad, can I expect my customer to register these substances for the EU? Example: we use 31 metals or metal compounds. How can we check?
  Yes, the importers are obliged to register the substances that they import above 1 tonne per year. As non-EU manufacturer, you have two solutions to ensure that you will maintain your business in EU: Communicate with all the EU importers to ensure that they will comply with their REACH obligations. Appoint an Only representative (art. 8) to take over the role of the importer in REACH and comply with all the REACH requirements.
• If you produce in “tolling” conditions, who should then register, the owner or the operator?
  The manufacturer has to register.
• Is mechanical equipment (e.g. engines) up for registration?
  Mechanical equipment should be dissociated into its various components. Most of them would probably be considered as articles but some could be regarded as preparations (e.g. battery???).
• Is the EU REACH System (registration) also of relevance for OECD countries?
  No.
• Is the registration number linked to the substance, to the company, or both?
  Not yet determined by the EC.
• No data, no market: does this mean that we have to register all substances that we can conceive of importing/manufacturing in the future? What happens if we start working with a new “material” that is phased-in and registered by somebody else after the time limits of registration have passed? We may import a substance after the end of pre-registration. Can we pre-register in anticipation of this to take advantage of phase-in timing?
  Companies which manufacture or import substances, on their own or in preparations, or produce or import articles containing substances in quantities of less than 1 tonne per year but which are planning to exceed the 1 tonne threshold after 1 December 2008 will also be entitled to pre-register and thus benefit from the transitional period. The pre-registration period will then start right after the first manufacturing or import exceeding the 1 tonne threshold, and will end 6 months later. However pre-registration will only be possible if it can be submitted 12 months before the relevant deadline for registration. First time manufacturers or importers will therefore have to submit their pre-registration by 30 November 2009, 31 May 2012 or 31 May 2017, whichever is relevant in view of their tonnage threshold.
• What happens in the case of a mixture of existing substances that are registered? Must the mixture also be registered? (mixture: no chemical reaction)
  No a preparation has not to be registered. A manufacturer or importer of a substance, either on its own or in one or more preparation(s), in quantities of 1 tonne or more per year shall submit a registration to the Agency.
• Will Switzerland, Iceland, Lichtenstein and Norway be considered as part of the EU for registration purposes?
  According to the corrigendum (published on 29 May 2007) of the REACH Regulation (EC) 1907/2006, Iceland, Lichtenstein and Norway (EEA countries) will be considered as part of the EU for all REACH requirement, including Registration. Importers of a substance from Switzerland will have the same obligations under REACH as any other importer.
• Will the Agency accept registrations from a non-EU entity that exports into the EU?
  No, the registrant has to be based in EU (EU manufacturer, Importer or Only representative appointed by a non-EU manufacturer).

Last page update: 1 October 2018