Article 5 of the REACH Regulation (“no data, no market”), that applies from 1 June 2008, states that substances shall not be manufactured in the
Community or placed on the market unless they have been registered in
accordance with the relevant provisions of Title II where this is required.
Placing on the market means supplying or making available, whether in return for payment or free of charge, to a third party. Import shall be deemed to be placing on the market (Article 3(12) of the REACH Regulation).
Based on these articles, it follows that: Substances manufactured before 1 June 2008 but not placed on the market in accordance with the definition above, need to be pre-registered (or registered as non phase-in substance) for being placed on the market after 1 June 2008. Quantities of substances on their own, in preparation or in articles that have already been placed on the market or imported before 1 June 2008 may be further used without (pre)registration provided that the placing on the market before 1 June 2008 can be documented.
แหล่งที่มา :ECHA_FAQ_version 2.3_2008-11-06
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