In order to benefit from the extended timelines and data sharing opportunities offered by the Substance Information Exchange forums (SIEFs), your substance must be preregistered. But you have just been told that your company has been offered a “great opportunity” and you are now going to be importing a really big shipment of a phase-in substance from China .
So you’re thinking, I only imported 700 kilograms per year before and I didn’t pre-register that substance. What do I do now?
If you are in the situation that as a manufacturer or importer you have just crossed the 1 ton per year threshold for the substance for the first time, then you have 6 months to preregister. In this example it was a really big shipment of 113 tons so you crossed the 100 ton per year threshold. At this volume you need to be aware that you only have until May 31, 2012 to preregister and benefit from the extended registration timeline.
REACH requires that a substance be preregistered 12 months prior to the relevant registration deadline. So the first thing you must do is prepare a preregistration and submit it prior to May 31st, 2012. Once preregistered and the “substance sameness” is confirmed, you will become a member of a SIEF and now have until May 31st, 2013 to register this newly imported substance.
H2 Compliance use their unique registration programme “Dossier Modus” to complete such late pre registrations using a 4 module approach that has proven itself time and time again.
If you are unsure of your registration status or need guidance in this area Contact Us today