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What are choices for substances below 1 tonne per year threshold?
Manufacturers/formulators and importers of "phase-in" substances in quantities of less than 1 tonne per year do not need to pre-register since registration is not required. However, they may do so if it is their intention to manufacture/formulate or import the substance in quantities of 1 tonne or more in the future.
It is important to note that manufacturers/formulators and importers that exceed the 1 tonne/year threshold after 1 December 2008 for the first time still need to pre-register and must submit the relevant information to ECHA within 6 months from the date where the 1 tonne threshold is first exceeded and provided this is at least one year before the relevant registration deadline.
Relevant registration deadlines
Pre-registration information has to be submitted to ECHA between 1 June 2008 and 1 December 2008. There is therefore a single pre-registration period for all "phase-in" substances. First-time manufacturers and importers are still entitled to pre-register after 1 December 2008.
A "first-time manufacturer or importer" is someone who manufactures, formulates or imports a substance in quantities of 1 tonne or more for the first time after 1 December 2008. The first-time manufacturer or importer (Art. 28.6) must pre-register:
They will therefore have to submit their pre-registration before 30 November 2009, 31 May 2012 or 31 May 2017, whichever is relevant in view of their tonnage bands.
- at the latest six month after its manufacturing or import exceeds the one-tonne threshold, and
- at least 12 months before the relevant deadline for registration.
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