10/27/2008

GiDoS s.p.r.l

(EC) REACH – Non-Phase-In Substances

Non phase-in substances can be broadly defined as the “new” substances which have not been manufactured, placed on the market or used in the EU before 1 June 2008. They include all substances that do not meet the definition of phase-in substance as given in the Regulation.

Non phase-in substances that are manufactured or imported in quantities of 1 tonne or more per year, will have to be registered by the company before the start of its activities involving these substances.

Process for Non-Phase-In Substances

1. INQUIRY

The inquiry process is essentially a three-step process whereby:

- The potential registrant must inquire with ECHA prior to registration if the same substance has already been registered;

- ECHA facilitates contact between the previous registrant(s) and the potential registrant(s) and/or other Potential Registrants, if any;

- Data sharing is organized between previous registrant(s) and/or Potential Registrants including for new tests to be potentially conducted
One of the main differences with the rules for phase-in substances is the early involvement of ECHA and its role in determining substance equivalence before facilitating contacts between registrants.


2. REGISTRATION

The actual registration dates for substances will vary from 2010-2018 depending on the quantity and risks of the substance.



It is vital to your company to appoint an Only Representative for this process (for both EU and non-EU manufacturers).

Contact us for more information (kasia@gidos) or visit our website: www.gidos.net


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