REACH Registration: The process, costs and requirements

The REACH Registration Overview

REACH Registration: the process Europe uses to understand & minimize the risks associated with quantities, types & suppliers of chemical substances imported

The basic goal of the European REACH regulation is to understand and minimize the risks associated with the quantities, types and suppliers of chemical substances into Europe. The REACH Registration process is the mechanicam by which this is done.

Do all chemical substances need to be Registered under REACH?

No, but most will. ECHA has established a lower limit of 1 ton, meaning that any chemical substance imported and sold into Europe greater than 1 ton per year will need to be registered under the European REACH regulation.

What is involved in the REACH registration process?

Essentially, the registration process involves submitting everything that is known to about the chemical substance to a committee of chemical experts to evaluate the level of risk of the chemical substance.

There is a very extensive technical dossier that needs to be submitted at the the time of registration. The dossier includes toxicological & eco-toxicological information, a chemical risk assessment, proposals for classification, and management recommendations of the identified risks among other things.

Who can register chemical substances?

Only companies that have an established European entity can register chemical substances. This means European chemical substance manufacturers, European chemical importers and distributors.

Foreign suppliers must register their chemical substances with a Europen "Only Representative". CAPLINQ is a REACH Only Representative and can register chemical substances on behalf of foreign chemical substance suppliers.

Learn more about the REACH Registration process

REACH Chemical Substance Registration

By June 1st, 2018 all chemical substances that enter Europe that exceed 1 ton per year need to be REACH Registered.

As of this writing (November 2013), Phase 1 and Phase 2 deadlines of the REACH Regulation Timeline have been passed. This means that currently, any chemical substances supplied at more than 100 tonnes per year needs to be registered. By the 1st of June 2018, this volume threshold will be lowered to 1 ton per year. Any chemical substances above this amount will need to be registered.

Do I need to register all the chemical substances I plan to supply into Europe?

By now, most of chemical substance supplied into Europe above 100 tons have already been registered. If you are supplying a chemical substance that has already been registered, and that may exceed 100 tons per year in the next year, then the REACH registration will be considered a "joint submission". A joint submission registration means that you essentially piggy-back on someone else's registration. In such cases, you will not need to register the chemical substance, but will be required to pay a "Letter of Access" fee to piggy-back on the registration.

What about chemical substances currently less than 100 tons per year?

As you can imagine, there are currently thousands of chemical substances that are supplied at more than 1 ton per year, but less than 100 tons per year. According to the REACH Regulation timeline, these substances may still be pre-registered. ECHA is currently building up a database of all the pre-registrations that have been done to be able to understand the amount of companies that will require REACH registration by 1 June 2018.

In most cases, CAPLINQ's approach is to pre-register chemical substances as early as possible (this is still free) and to delay registration (which could be expensive) until there is a clear picture of the number of possible registrants. As a trusted ORO member, CAPLINQ is in touch with the people who receive and review these REACH registration dossiers.

Learn more about the REACH Registration process