INTRODUCTION | LEGAL BACKGROUND | HISTORY OF THE LEGISLATION | BASIS OF REACH | EXEMPT MATERIALS | DEFINITIONS | PRE-REGISTRATION | SIEF FORMATION | SUBSTANCE SAMENESS | DATA EVALUATION | CONSIDERING NEW TESTING | THE EXPOSURE SCENARIO | RISK ASSESSMENT | COMMUNICATION |
REGISTRATION PROCESS | SPECIAL CASES | DOWNSTREAM USER OBLIGATIONS | AUTHORISATION AND RESTRICTION | AFTER REGISTRATION | ABBREVIATIONS

SPECIAL CASES - NON-PHASE IN, INQUIRIES, PPORD, INTERMEDIATES

Most REACH guidance considers the majority of chemical substances that were eligible for phase-in and will be covered by SIEFs. However, certain types of chemicals do not fit into this main category

Non-phase in : substances not on EINECS or not considered exempt from EINECS under the old system (ie. export only substances or site limited intermediates) need immediate registration as they cannot be pre-registered.

Inquiries : if making a non-phase in registration, it is first essential to make an Inquiry using IUCLID 5. These needs a comprehensive set of analysis data on your production / import material so that ECHA can compare with other registered substances. If the same as other substances or similar (eg. substance Notified under NONS with an ELINCS number) then you will be asked to work with the data holder to share animal data. If the data was submitted over 12 years before your Inquiry, the data will be freely available.

PPORD : the REACH Production and Process Orientated Research and Development exemption is very much the same as the PORD under NONS, but allows a longer period of supply (normally up to 5 years) and has no real limit for volume. There are no formal test requirements for PPORDs, but remember that classification and labelling is required and an SDS is needed.

Intermediates : substances that are used exclusively for conversion to other chemicals and which are closely controlled (ie no supply to the general public and limited exposure to workers or the environment at named sites) need less testing for registration. Non-isolated intermediates do not need registration.