What is a Phase In Substance?

These are Chemical Substances which will be ‘phased in’ to the REACH regulation.

They fall into one of three categories:

·         Current EINECS substances

·         Substances manufactured in the EU, but not placed on the market before REACH came into effect (i.e. 01 June 2007)

·         NLP (No Longer Polymer) substances

Again, all of these substances must be pre-registered to enjoy the phase-in period benefit prior to full registration requirements – if not pre-registered, full registration will be required BEFORE substance is manufactured and/or imported into the EU.

There are two types of Non-Phase In substances with different registration requirements.

So-called ELINCS Substances

·         These are substances which were notified under the previous scheme from 1981 onwards with a toxicity data set based on volume.

·         The substances are considered to be already registered under REACH.

·         The ELINCS registration number will be converted to a REACH registration number by the end of 2008.

Any ‘New Chemical’ invented after 01 June 2007 and manufactured/imported at > 1 MTPA per legal entity

·         The substances must be registered (not pre-registered) under REACH immediately.

o    > 1 to 10 MTPA at a cost of about $70,000

o    > 10 to 100 MTPA at an additional cost of about $280,000

·         This is analogous to the previous EU scheme for new chemicals where a notification was required before supply in the EU.