All substances on the market in the EU must be “preregistered” with the authorities by 1 December 2008. Any not preregistered can no longer be made or sold from this date without being fully registered. Preregistration is free, registration is costly and may take over a year. Do you have continued assurance of supply of all the materials you use?

REACH is a new, EU wide regulation affecting the availability and allowable use of practically all chemicals and materials used in manufacturing in the EU either on their own or in finished products. The first major event in the role out of REACH starts 1 June 2008 when importers or manufacturers of chemicals and materials already on the market in the EU can “pre-register” them. This is only required where the substance is imported or manufactured in the EU in quantities greater than 1 tonne per annum.

Pre-registration is, free and the information required is relatively basic:

	name(s) of the substance (using appropriate standard forms)
	name and address of the pre-registrant and the name of the contact person
	details of discussions with other Manufacturers, Importers and Downstream Users as specified in Article 4 of the regulation
	the envisaged deadline for registration and tonnage band
	the name(s) of other substance(s) for which the available information is relevant for performing adaptations to the testing requirements (for example other members of a family of substances such as the polybrominated diphenyl ethers).

In most cases manufacturers of engineering products or parts will expect their suppliers to deal with this. However, it is worth checking that they understand their obligations and are responding in time. In many cases this will require them communicating further up the supply chain.

Even so there are two situations where you should seriously consider preregistration yourself:

	If you import materials directly from outside the EU. If you import materials including metals, plastics, paints, etc. directly from outside the EU then you are the importer and should pre-register if the tonnage of any substance within these exceeds more than 1 tonne per annum.
	As a precautionary step. If you are unsure that a particular substance is not going to be preregistered then do so yourself. The effort required is minimal and there is no obligation to follow and register. Conversely, therefore, preregistration by your supplier is no guarantee they will continue to provide a substance

Pre-registration closes on 30 November 2008. If the deadline is missed the substance cannot be manufactured or put on the market in the EU until it is registered, a process which could easily take over a year and is very costly.

Further information
ERA runs courses on REACH compliance and publishes a comprehensive REACH guide for the electrical products sector (in REACH jargon “downstream users” and manufacturers or importers of articles). To find out more call us on +44 (0)1372 367444 or email.