REACH Update: The REACH Schedule

Registration under REACH starts on June 1, 2008, when manufacturers and importers of new substances in quantities above 1 ton have to submit a registration to the European Chemicals Agency. The agency was established in Helsinki on June 1, 2007, when REACH went into effect. Companies may start manufacturing or importing three weeks after registration as long as there is no objection by the agency. Until June 1, 2008, the old notification scheme under Directive 67/548 applies.

The date June 1, 2008, marks the start of the six-month period of pre-registration for phase-in substances, allowing these to benefit from an extended registration time frame. Consequently, three months remain for getting prepared and to perform these important steps:
-Assessment of the product portfolio
-Concluding on substances that need to be registered
-Deciding to pre-register or register directly
-Deciding to pre-register as a manufacturer or an importer, through an ‘only representative’ or through a ‘third party representative’

Companies that start manufacturing phase-in substances after the end of the pre-registration phase still may decide to join the pre-registration processes and SIEFs. For this, they must submit the pre-registration information within six months from the start of manufacturing or importing and at least 12 months before the relevant registration deadline.

A potential registrant of a phase-in substance who has not pre-registered has to inquire from the agency if a registration has already been submitted for the same substance. An inquiry is also requested from every potential registrant of a nonphase-in substance. The potential registrants have to request  all information about tests on vertebrate animals required for registration from the previous registrant(s) (Article 27).

Key summary:
• REACH provisions will apply on June 1, 2008.
• Nonphase-in substances have to be registered under the REACH provisions, including inquiry, as of that day.
• Phase-in substances benefit from extended registration deadlines if they will be pre-registered.
• The pre-registration phase is from June 1-Nov. 30, 2008.
• A potential registrant who starts manufacturing a phase-in substance after the end of the pre-registration phase may still join the processes and SIEFs until 12 months before the relevant registration deadline.
• All potential registrants of new substances or nonpre-registered substances have to inquire from the agency if a registration for the same substance has already been submitted.

-Annelie Struessmann
 Technical director, CONUSBAT

Next month’ topic: Specific provisions for naturals and polymers

Further questions? Go to C&T’s REACH Round Table

Further useful information:
REACH Workshop: Final countdown to pre-registration and registration of chemicals
Organized by the European Commission and the European Chemicals Agency
Apr. 14, 2008 in Brussels

New Guidance Documents on REACH:
Guidance on registration (update) - 02/18/08
Guidance for intermediates (update) - 02/18/08
Guidance on PPORD (update) - 02/18/08
Guidance for Downstream users - 01/29/08

Readers are reminded, that the text of the REACH Regulation (Regulation(EC) No 1907/2006 is the only authentic legal reference. The information in this document does not constitute legal advice.

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