How to update your previously notified substance (NONS)

How to update your previously notified substances (NONS)

Substances notified under the Notification of New Substances (NONS) scheme of Directive 67/548/EEC – that was in place before REACH – are considered as registered.

Each notification under Directive 67/548/EEC was assigned a registration number in 2008. You could claim the registration number assigned to your NONS notification until July 2022.

If you did not claim your registration number, and want to restart manufacture or import, you must register your substance under REACH as a new registrant.

NONS registrants also have to update their registrations, and the REACH information requirements are different from those under Directive 67/548/EEC. However, updating does not necessarily mean that you need to provide all the information required under REACH. You can find which information you will need for updating such registrations in Annex 4 of the ECHA manual ‘How to prepare registration and PPORD dossiers’. This will depend on the situation you are in.

In any case, your registration update must include the classification and labelling in accordance with CLP, and it will undergo a completeness check in line with the situation you are in as described in the sections below.

For updates to increase the tonnage band or to become the lead of a joint submission the dossier must satisfy all information requirements under REACH.

The following steps explain how you can update the registration of your previously notified substance.


1. Join a joint submission or create one

Your notification under Directive 67/548/EEC was included in ECHA’s database as an ‘individual registration’. However, as any registrant, you must submit jointly.

Therefore, before you update, check if there is a joint submission for the substance. If there is a joint submission, you need to join it.

If there is no joint submission for the substance, you should discuss with the other individual registrants and potential registrants about creating a joint submission and appointing a lead registrant. If there are no other (potential) registrants, you can either:

  • create the joint submission yourself and become the lead registrant with your registration update, or
  • update your individual registration. In this case, if another registrant later creates a joint submission for your substance, you will need to join the joint submission before the next update of your registration.

You can find more information on the steps you need to take to join a joint submission in phase 2 of the Registration phases ‘Finding your co-registrants’, or to create a joint submission in phase 3 ‘Get organised with your co-registrants’.


2. Retrieve your scientific information in IUCLID 6

Download your registration dossier from REACH-IT. Then, import it in your IUCLID database and extract the information from your dossier into a dataset to start working on your dossier update.

If all your submitted data is not available in the dataset, contact the Member State Competent Authority of the country where the notification was submitted to request it.


3. Updating as a lead registrant

The jointly submitted information on your substance needs to satisfy the REACH information requirements. The jointly submitted information for a standard (full) registration needs to cover as a minimum the requirements for registration in the 1-10 tonnes per year band.

If your tonnage band is higher, you can submit the additionally required information separately (as an opt-out). As a previous NONS notifier, the information you submit separately can contain derogations due to the substance being previously notified under Directive 67/548/EEC.


4. Updating as a member registrant

If a joint submission exists for your substance, you need to join as a member registrant. After that, you can submit an update as a member registrant.

If you will rely on the information jointly submitted by the lead registrant, you only need to update your own information, such as the composition of your substance, the quantities manufactured or imported and the uses of the substance in your supply chain.

If you will not rely on all or some of the information jointly submitted by the lead registrant, you will need to submit that information yourself (as an opt-out). If your current manufactured or imported quantities do not reach the next tonnage band threshold, you can make derogations to some of the information requirements due to the substance being previously notified under Directive 67/548/EEC.


5. Updating to a higher tonnage band

You must update your registration if the quantity you manufacture or import of the substance reaches the next tonnage band threshold. You can find the timeline for updating from Respect the deadlines for updating.

The update must satisfy the information requirements under REACH and pass the standard completeness check for the new tonnage band. You can no longer make use of derogations due to the substance being previously notified under Directive 67/548/EEC.

Start by submitting an inquiry to ECHA and discussing with your co-registrants.


6. Updating your confidentiality requests

Review if the information in your notification for which confidentiality was accepted by the Member States under Directive 67/548/EEC still requires confidential treatment. If so, you need to indicate this in your update.

If you are requesting confidentiality on new information in your update, you will need to justify it and pay the fee as any other registrant.

Further information on confidentiality requests under REACH is available in the manual ‘Dissemination and confidentiality under the REACH Regulation’.

The following IUCLID tools are helpful in the preparation of your update:

  • The Dissemination Preview tool simulates which information from your dossier will be published on the ECHA website;
  • The Fee Calculator tool calculates the costs of your confidentiality requests and any other fees associated to your registration.


7. Updating to notify a cease of manufacture or import

If you no longer manufacture or import a substance, you must notify the cease of manufacture or import to ECHA using the functionality ‘cease manufacture or import’ available in the ‘Reference number page’ of the substance in REACH-IT.

Ceasing manufacture or import is reversible – meaning that you can restart manufacture or import with the click of a button, without needing to register again – unless you ceased manufacture or import after having received a draft evaluation decision. More information is available in the practical guides ‘How to act in a substance evaluation’ and ‘How to act in a dossier evaluation’.

How to update your previously notified substance related