Outsourced Registration Services
3E’s team can work collaboratively with you to submit and collect data for late pre-registration, including the identification of substances to determine possible authorization requirements.
The late pre-registration may be of value for potential registrants who, for the first time after 1 December 2008, manufacture or import a phase-in substance in quantities above 1 ton per year but no more than 100 tons per year. They can still submit certain information to ECHA (late pre-registration) and benefit from the extended deadline for EU REACH registration as of 1 June 2018. Producers and importers of articles with an intended release of a substance can also submit a late pre-registration.
Late pre-registrations must be submitted within six months after the manufacturing or importing of the substance that exceeds the one-ton threshold and no later than twelve months before the relevant registration deadline. Therefore, the late pre-registration period ends on 31 May 2017 for substances to be registered by 31 May 2018.
3E can work with companies to submit the required annual report of chemicals imported in amounts greater than 1,000 kg/yr. Annual reports are due June 30 starting in 2016.
The team can also help companies develop a strategy and implementation plan for the required registration of chemicals that starts in 2020 and for preparation of Chemical Safety Reports starting in 2017 for chemicals listed on the Priority Existing chemicals list.
3E’s Regulatory Consulting Services team can address the following areas:
- Prior to import, prepare and submit chemical notifications to the Korea Chemical Management Association (KCMA) for any chemical not listed on the Korean Existing Chemical Inventory (KECI)
- Register under Act on Registration and Evaluation (AREC), aka K-REACH, any “designated existing chemical substances” (PEC) for annual volumes greater than 1,000 kg/yr and any new chemical at any volume when a chemical notification is submitted
- Report under K-REACH annually the quantities and uses of all registered new chemicals at any volume and existing chemicals that are imported in quantities of 1 metric ton or more per year
- Facilitate Only Representative (OR) services required for foreign entities to act as qualified representative for notification and registration submissions
- Prepare and submit Chemical Safety Reports (CSR) for chemicals imported at levels greater than 10 metric ton
3E Company can also act as a third party representative to EU companies during the pre-registration period to prepare the documentation and help clients understand the process. As a third party representative, we act and participate on the company’s behalf in SIEFs (Substance Information Exchange Forums). This is helpful for companies who want to keep the fact that they use certain substances in their products confidential from competitors. 3E Company is listed on the pre-registration, protecting the company from disclosing their name during the registration process. Complying with REACH is ultimately the company’s responsibility, but 3E Company can provide valuable guidance to meet the complex requirements. 3E Company does not perform any work with the technical guidance document, or develop Chemical Safety Reports, but has established partnerships with consultancies to which we can refer you.
Non-EU companies must assign an Only Representative, which acts as the EU company importing the substances into the EU. If your company needs an Only Representative, 3E Company can refer you to one of our partners.