Practical sheet | REF: FIC0142 V1

Manufacture of a substance: determining whether this is a placing on the market within the meaning of the REACh regulations

Author: Gautier VINCENT

Publication date: July 10, 2011, Review date: October 4, 2016 | Lire en français

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3. When is a substance manufactured and then stored put on the market?

A manufactured substance that is then stored is not placed on the market. Only the sale of the stock is considered to be placing on the market.

The status of the legal entity placing the stored substance on the market may vary depending on whether or not the substance is still being manufactured:

  • If production of the substance is stopped before the regulatory deadline defined by annual tonnage, the legal entity no longer has manufacturer status. When it disposes of its stock of substances, after the regulatory registration deadline, it will be considered a substance distributor. It will have no obligation to register its substance, even though it is placed on the market. The legal entity must have documented proof of the date of manufacture/importation, of the date of cessation of manufacture/importation and of pre-registration...

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When is a substance manufactured and then stored put on the market?