Companies starting to manufacture or import a phase-in substance in amounts of one tonne per year or more after 1 December 2008 can submit a late pre-registration and still benefit from the extended registration deadlines. Producers and importers of articles with an intended release of a phase-in substance can also submit a late pre-registration.
Late pre-registrations have to be submitted:
- within six months after exceeding the one tonne per year threshold; and
- no later than 12 months before the relevant registration deadline.
Therefore, late pre-registrations can be submitted until 31 May 2017 for substances that need to be registered by 31 May 2018. The 2018 deadline concerns phase-in substances manufactured or imported in quantities below 100 tonnes per year, which are not cancerogenic, mutagenic or reprotoxic (CMR) category 1A or 1B. Other phase-in substances can no longer be pre-registered.
For substances which cannot be pre-registered anymore, or substances for which the company decides not to pre-register, potential registrants need to submit an inquiry to ECHA before registering.