Under the REACH regulation, all chemical substances manufactured or imported in quantities of one tonne or more per year and falling within its scope of application must be registered with the European CHemicals Agency (ECHA) before being manufactured or placed on the market in the European Economic Area (EEA), i.e. the 27 EU Member States, Iceland, Liechtenstein and Norway.
Companies wishing to register chemical substances are obliged to inquire with ECHA whether the same substance has already been registered before proceeding with their registration.
Potential registrants must therefore submit a prior request for information (inquiry) to ECHA. On the basis of the information received, ECHA determines whether the substance in question has already been registered or if there are other potential registrants for the same substance.
This allows potential registrants to:
- determine whether a registration was submitted by another registrant for the same substances;
- inform ECHA of their information needs relative to a given substance;
- share available data with other registrants or potential registrants of the same substance and work with them to submit a joint registration thereof.
Who is concerned
As of 1 January 2020, substances that had been pre-registered have had their pre-registration voided. This means that all potential registrants of a substance are concerned by the procedure of prior request for information.
Potential registrants should pay specific attention to the substance identity information they provide to allow unequivocal substance identification.
They are advised to check the ECHA website to see whether the substance is on the list of either pre-registered or registered substances.
How to proceed
Submitting an inquiry
An inquiry file is prepared as follows:
- by first creating the file using the most recent version of IUCLID;
- and then submitting it on the REACH-IT platform (IUCLID detects any missing information thanks to its control plug-in and to carry out a prior check of certain "administrative rules").
Once the inquiry is received, ECHA checks to make sure the file is complete.
Potential registrants need to wait for the result of the inquiry before submitting the registration file or starting any tests on vertebrate animals.
The result of the inquiry may trigger legal obligations to submit a joint registration and share data.
Depending on the information provided in the application files, ECHA directs applicants to the corresponding co-registrant page in REACH-IT, where they can find contact details of other registrants and potential registrants of the same substance.