REACH Late Pre-registration

In accordance with REACH, phase-in substances("existing substances") enjoy benefits of varied extended registration deadlines if pre-registered before 1 Dec 2008. The principle is that the higher the tonnage is, the earlier the registration deadline is (2010, 2013 and 2018).

REACH pre-registration ended on Dec 1 2008. However, non-EU manufacturers/EU importers/EU manufacturers who first began manufacturing or placing phase-in substances on the European market in excess of 1t/year after 1 Dec 2008, still can benefit from extended REACH registration deadlines by submitting a late pre-registration to the European Chemical Agency. Non-EU companies shall appoint EU-based REACH Only Representative to do so.


If your company plans to put a phase-in substance on EU market for the first time this year  and you predict the volume to be 100-1000t/y, you shall act now and submit your late pre-registration before 31 May 2012 to benefit from extended registration deadlines.

Note: Late pre-registration is much cheaper and easier than registration and it should always be your first choice if you qualify for it. If you(EU importers or non-EU companies) missed REACh pre-registration and do not qualify for late pre-registration, you need to register your substance immediately before you export your product to EU. Please contact us for free advice.

What is meant with extended registration deadlines?

Article 23 of the REACH Regulation provides for a scheme with staggered registration deadlines for so-called ’phase-in substances’, depending on the tonnage band and hazards of the substance. The respective deadlines to submit the registration dossier to ECHA are as follows:

  • 30 November 2010 for CMR1 ≥ 1 t/y, R 50-532 ≥ 100 t/y and other substances ≥ 1000 t/y; or
  • 31 May 2013 for other substances ≥ 100 t/y; or
  • 31 May 2018 for other substances ≥ 1 t/y;

How do I know if I qualify for a late pre-registration?

You may submit late pre-registration after 1 December 2008 if you are:

  • able to prove that you are established in the European Community and manufacturing or importing phase-in substances (on their own or in a preparation or in articles intended to be released) for the first time after 1 December 2008 in quantities of 1 tonne or more per year;
  • non-EU companies exporting phase-in substances (on their own or in a preparation or in articles intended to be released) for the first time after 1 December 2008 in quantities of 1 tonne or more per year may appoint REACH Only Representative to submit late pre-registration to relieve the obligations of EU importers under REACH.

If this is the case, the following deadlines apply:

  • At the latest six months after manufacturing or importing exceeds the one-tonne
    threshold; and
  • at least 12 months before the relevant transitional deadline for registration.


If you missed pre-registration and do not qualify for late pre-registration, please see our registration service or consult us for free advice.

What information is to be submitted in a late pre-registration?

  • Substance identifier(IUPAC name, CAS, EC);
  • The name and address of the potential registrant;
  • Contact person for furter communications;
  • The envisaged registration deadline;


About CIRS

CIRS a leading provider of comprehensive chemical compliance services for companies doing businesses in/with EU and China with a strong focus on chemical compliance.

With a strong presence in EU and China, CIRS has provided cost-effective regulatory support to over 3,000 companies while doing businesses in both the EU and China.

CIRS is the largest REACH only representative in the world. Since 2007, we have:

  • pre-registered over 10,000 substances;
  • acted as only representative for over 2,400 non-EU companies;
  • served clients in more than 25 countries;
  • registered over 145 substances to date;
  • prepared over 1000 REACH SDS and CLP labels to date;
  • submitted over 500 C&L Notifications to date;

CIRS is a recommended service provider by China Inspection and Quarantine Bureau, the US Mission to the EU and IDA. CIRS is also a member of Helsinki REACH Centre.


  • Europe Office
    Unit 1 Ardee Business Park, Hale Street, Ardee, Co. Louth, Ireland
    Tel : +353 41 9806 916 | Fax : +353 41 9806 999

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