The approach to the new REACH European regulatory framework for chemicals has been documented by this column for more than one year. Looking back to earlier columns, the learning curve was influenced by the publications of the ECHA, and is clearly illustrated by the supportive efforts of the chemical associations, and by companies practically performing the steps required by REACH. The industry has met the end of the preregistration phase now; however, it will not stop meeting new challenges posed by future phases.
The past weeks of preregistration involved finalizing the substance inventories performed via preregistration on REACH-IT. Although REACH-IT proved to be an impressive communication tool, which is easy to handle and quick in response, it required several updates with additional capacity upgrades from its first launch on June 1, 2008, until today. Unfortunately, REACH-IT was not always accessible for submitting preregistrations, thus the majority were made during the past few weeks. As of Nov. 26, 2008, the total number of preregistrations totaled 1,757,218, with almost 40,000 companies registered for a REACH-IT account.
ECHA informed the industry that because the preregistration deadline was set forth by the REACH regulation, it will not be extended. In case the influx of last-minute preregistrations could not be absorbed by REACH-IT, and as such it would not be accessible during the final phase of preregistration, a backup submission procedure was developed to allow direct submissions via a form on the ECHA Web site; however, preregistrations on paper, by e-mail, or through the information request Web forms on ECHA’s Web site cannot be accepted. Also, from Nov. 17–Dec. 1, 2008, ECHA offered enhanced assistance to companies that still required help for timely preregistrations. The preregistration phase ended at 12:00 a.m. on Dec. 1, 2008 (GMT).
After Dec. 1, 2008, preregistrations can only be made by registrants who, for the first time, manufacture or import a phase-in substance in quantities of one ton or more per year. This preregistration must be submitted within six months of the first manufacture, importation or use of the substance, as per Article 28 (6).
With preregistrations made, the industry now moves to identifying the SIEFs to exchange and evaluate data, and to file the registration dossiers. New challenges and questions will appear, as the steps toward the first deadline gave the industry exposure and confidence for meeting future requirements.
-Annelie Struessman, PhD, CONUSBAT
Readers are reminded that the text of the REACH Regulation (EC) No 1907/2006 is the only authentic legal reference. The information in this document does not constitute legal advice.
Do you have further questions? Visit C&T magazine’s REACH Round Table.
Draft guidance on Waste and Recovered Substances: http://ec.europa.eu/enterprise/reach/docs/reach/waste_paper_ca_081026_en.pdf