What is a Phase In Substance?

These are Chemical Substances which will be ‘phased in’ to the REACH regulation.

They fall into one of three categories:

• Current EINECS substances
• Substances manufactured in the EU, but not placed on the market before REACH came into effect (i.e. 01 June 2007)
• NLP (No Longer Polymer) substances

Again, all of these substances must be pre-registered to enjoy the phase-in period benefit prior to full registration requirements – if not pre-registered, full registration will be required BEFORE substance is manufactured and/or imported into the EU.

There are two types of Non-Phase In substances with different registration requirements.

So-called ELINCS Substances

• These are substances which were notified under the previous scheme from 1981 onwards with a toxicity data set based on volume.
• The substances are considered to be already registered under REACH.
• The ELINCS registration number will be converted to a REACH registration number by the end of 2008.

Any ‘New Chemical’ invented after 01 June 2007 and manufactured/imported at > 1 MTPA per legal entity

• The substances must be registered (not pre-registered) under REACH immediately.
  • > 1 to 10 MTPA at a cost of about $70,000
  • > 10 to 100 MTPA at an additional cost of about $280,000
• This is analogous to the previous EU scheme for new chemicals where a notification was required before supply in the EU.

This document is provided for information purposes only and does not constitute legal advice.  While every effort has been made to ensure the accuracy of the information contained herein, The Lubrizol Corporation cannot be held liable for any errors in or any reliance upon this information.