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 28 EU Member States, Iceland, Liechtenstein and Norway.
Companies wishing to register non-phase-in substances or phase-in substances that were not pre-registered have to submit a request for information prior to registration.
This prior request for information, known as an inquiry, must be submitted 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 pre-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
Potential registrants of non-phase-in substances or phase-in substances that were not pre-registered must submit an inquiry.
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 either the list of pre-registered or registered substances.
How to proceed
Submitting an inquiry
An inquiry may be prepared and submitted in one of two ways:
- either directly via the REACH-IT platform;
- or by creating the dossier using the most recent version of IUCLID 5 and then submitting it via the REACH-IT platform (IUCLID 5 has a plug-in to detect any missing information and check that certain administrative rules are complied with before submission).
When the inquiry is received, ECHA checks to make sure the dossier is complete.
Potential registrants need to wait for the result of the inquiry before submitting the registration dossiers or starting any tests on vertebrate animals.
The result of the inquiry may trigger legal obligations to submit a joint registration and share data.