REACH Update: A Status Report Nearly One Year Before the First Registration Deadline

By: Annelie Struessmann, PhD, CONUSBAT

Posted: October 20, 2009

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On Sept. 30, 2009, the number of SIEFs with active LRs totaled 1,766, as published on the ECHA Web site. In addition, the number of submitted registration dossiers in August 2009 reached 578, with only 109 registrations completed.

As the first deadline will be reached in December 2010, all these steps will have been performed in less than two years, as the ECHA performs checks on completeness of the dossiers. Checking that all requirements are met will take several weeks, especially if a registration dossier is found to be incomplete and/or the payment of the registration fee is missing.

If this is the case, the registrant will be granted a period of time for re-submission; however, if the registrant fails to complete the submission within the given deadline for a second time, the ECHA will reject it. It should also be noted that after a rejection, the registration fee will not be reimbursed and the company will not be allowed to manufacture or import this substance within the EU. And if the registration is made by a lead registrant, the consequences will apply to all joint registrants.

Key Summary
• The challenges of REACH are based in a large quantity of legal texts and require comprehensive technical skills
• All the steps to compliance must be taken in a yet-unknown environment
• For the dissemination of REACH contents, ECHA provides guidance documentation and videos as well as stakeholder events
• The formation and management of SIEFs still involves difficulties
• ECHA will provide further guidance tools to support SIEFs, specifically in support of LRs
• LRs bear the main responsibility for registration
• Failed completion of a registration leads to rejection, a non-reimbursable registration fee, and ceased manufacture or importation in the EU
• The consequences of a rejection apply to all registrants in a joint submission

To read or submit additional questions regarding REACH, visit C&T magazine online's REACH Round Table.