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Does the REACH 2018
registration deadline affect you?
The last leg of the journey to having a full picture of the chemicals on the EU market is well on its way. By 31 May 2018, the European
Chemicals Agency expects to have received information on up to 30 000 chemicals used in the European Union on a daily basis.
The REACH 2018 deadline affects companies that manufacture or import existing (phase-in) chemicals in the EEA above one tonne
per year. ECHA and industry have already successfully managed the first two deadlines of 2010 and 2013 for the higher tonnage
and more hazardous chemicals.
For the last deadline, we expect a substantial number of the registrations to come from inexperienced and small and medium-sized
companies. There will also be a lot of new data to be shared and generated to fill in the information requirements for these substances.
To help companies in this task, we provide a roadmap to successful registration where we split the registration into seven phases.
Each phase contains a different topical theme, and ECHA’s support material for that topic is organised in three layers of complexity
(getting started, essential reading and getting deeper). Our REACH 2018 web pages, available in 23 languages, are a one-stop
shop for all this material.
In the
first phase
, companies need to make sure they know their portfolio of substances in REACH terms and make a plan for
registering their substances by the deadline. At this point, they need to consider which substances they want to have in their
portfolio in the future and for this, listen to their customers. It is also topical to consider whether the company has the expertise it
needs to manage the whole registration process or whether it needs to look for a consultant.
The
second phase
is about finding co-registrants as REACH requires companies registering the same substance to work together
in a substance information exchange forum (SIEF) and register jointly. If a substance is already registered, a SIEF exists and new
registrants will need to join it. All registered substances can be checked on ECHA’s website. If a substance is not registered, the co-
registrants will need to contact each other to form a new SIEF. The contact details of the companies that have pre-registered with
the same substance identifier (e.g. EC number) can be found on the pre-SIEF page of the dossier submission tool REACH-IT.
The
third phase
calls for companies to get organised with their co-registrants. They must agree how to work together and communicate
with each other. The key is to come up with fair, transparent and non-discriminatory ways of sharing data and the related costs.
An important part of the registration is the
fourth phase
on assessing the hazards and risks: companies must compile data on the
properties and uses of their substance to be able to demonstrate how it can be used safely. The following regulatory, scientific and
technical requirements need to be considered:
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Information on uses and current conditions of use from the supply chain.
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Hazard data as requested by REACH information requirements triggered by the tonnage and uses of the substance.
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The coverage and quality of the hazard information about the substance available within the SIEF, making sure that this
information is suitable for all compositions and forms of the substance, which will be registered jointly.
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The strategy to fill in any resulting data gaps keeping in mind that animal testing is to be used only as a last resort.
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The classification and labelling (based on the hazard data).
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All hazard data and classification in the registration dossier.
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If manufacturing or importing more than 10 tonnes per year, companies must carry out the chemical safety assessment and
record it in a chemical safety report (CSR). Otherwise, they need to provide guidance on safe use.
Next, in the
fifth phase
, the lead registrant and each member should have all the relevant information available to create their
registration dossiers. In practice, this is done using the IUCLID software which is available on ECHA’s website free-of-charge.
In the
sixth phase
, companies will submit their registration through the REACH-IT tool.
The
final step
is about keeping the information in the registration up-to-date whenever new information becomes available.
As said, the last registration deadline will complete what started already in 2008: collecting information on all the chemicals in use
on the European market. It is yet another important milestone towards the
safer use of chemicals in Europe
and I invite you all to
start your preparations now
.
REACH 2018 web pages:
Registered substances:
Free access to REACH terminology:
/
ECHA’s Stakeholders’ Day – register now at:
EDITORIAL
CHRISTEL MUSSET
European Chemicals Agency
Christel Musset
Chimica Oggi - Chemistry Today
- vol. 34(2) March/April 2016
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