REACH Update: Pre-registration
Posted: October 7, 2008
By Sept. 15, 2008, a total of 352,641 pre-registrations were received by the European Chemicals Agency (ECHA). Of these registrations, the greatest number—141,185—were submitted by German entities. In a Sept. 19 news alert, the ECHA noted that some of these pre-registrations may not be valid, primarily because phase-in obligations were not fulfilled, or the Only Representative status did not comply with provisions of the REACH regulation.
In addition, the ECHA discovered that two companies pre-registered the entire European Commission (EC) inventory, which is a practice that is not in accordance with pre-registration and that makes participation in SIEFs unmanageable. As a result, the ECHA has requested that companies pre-register only the substances they intend to register, and to restrict the number of substances submitted in bulk pre-registration files to 10,000. Companies that have to pre-register more than 10,000 substances should contact the ECHA help desk for approval.
In a case where the ECHA doubts the validity of a submitted pre-registration, the companies concerned will be contacted for clarification. Pre-registration submissions can be deleted from record by sending a request via registered mail to the ECHA. Retracted pre-registrations and the pre-registrations submitted by the two companies covering the entire EC inventory will not be included in the intermediate list of pre-registered substances, which was anticipated to be published in October.
Meanwhile, REACH-IT reportedly is limiting access on occasion due to either an overload or lingering technical difficulties. Pre-registrants should build these potential barriers into their submission schedule. Questions that frequently appear asking how to use the REACH-IT system are now addressed under a new link that was recently added to the ECHA Web site.
Successfull submissions via REACH-IT are indicated by the assignment of an individual pre-registration number for a substance. There is no legal requirement to communicate this pre-registration number within the supply chain. and the provision of the number by a supplier does not guarantee future compliance with REACH or continuity of supply.