A number of these pre-registrations may not be valid. ECHA would like to remind companies that before they submit a pre-registration REACH-IT requires them to declare that the substances they pre-register are phase-in substances within the meaning of Article 3 (20) of the REACH Regulation (REACH). Only representatives are also reminded that, according to Article 8 of REACH, they can only be appointed by a person outside the Community who manufactures a substance, formulates a preparation or produces an article that is imported into the Community, and that the documents showing this must be available. Certain pre-registrations ECHA has received are in breach of Article 3 (20) or Article 8 of REACH. Companies who have submitted such pre-registrations may therefore be subject to enforcement actions by the authorities of the relevant Member States. Furthermore, ECHA has received pre-registrations made by two companies, covering the entire EC inventory. This practice should not be followed as it is not in accordance with the aim of pre-registration which is designed for data sharing in advance of the registration. Preregistration of the entire inventory impacts heavily on the usefulness of the list of preregistered substances. On the one hand, for a company pre-registering the whole inventory participation in the Substance Information Exchange Fora (SIEFs) will become unmanageable. On the other hand, this is in particular disadvantageous for downstream users, who should be able to notify ECHA of their interest in a substance not appearing on the list of pre-registered substances, according to Article 28(5) of REACH. Consequently, ECHA requests companies to pre-register only the substances they intend to register. It also appears from some pre-registrations that the name of the substance does not refer to any chemical name that could be used for the purposes of a SIEF. In those cases where ECHA has doubts on the validity of a submitted pre-registration, the companies concerned are being contacted to clarify their pre-registrations. Companies wishing to have a preregistration deleted can send their request by registered mail to ECHA In addition, companies should note that ECHA will restrict the number of substances that can be submitted via bulk pre-registration files at 10,000. If a company would like to pre-register more than 10,000 substances they need to contact the ECHA Helpdesk for prior approval.
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