Benefits of Early Registration for Nov. REACH Deadline
The deadline for REACH registration is 30 November 2010 for the registration of high volume and potentially toxic substances. In order to be in compliance, companies or their representatives must register by that date.
There are notable benefits for registering before the drop-deadline, as itemized by a recent report from ECHA, the European Chemicals Agency. Risk-mitigation is the largest benefit. (For an overview of REACH regulation, see previous post on the Top Ten FAQs about REACH.)
Companies are accelerating their efforts to gather the necessary data, reports ICIS.com. Software solutions for REACH compliance can help some companies streamline operations and mitigate risk associated with chemical management in a product supply network. Still, even if using software, it is important to have an understanding of the big picture.
The November cut-off, the first of three Reach registration deadlines, covers dossiers for chemicals produced or imported in annual volumes of 1,000 tonnes or more. It also covers registration of substances which are carcinogenic, mutagenic or toxic to reproduction and chemicals used in quantities above 100 tonnes per year that pose long term risks to aquatic organisms, as stated by the RSC.
Benefits of submitting before October 1st are:
Resubmission
Companies that submit dossiers early (before 1 October) will get their Completeness Check result within 3 weeks and will have the time to resubmit. Should they fail the second time, they can even start the process again provided they are in a position to make a new submission before 1 December.
Later submissions will have only one chance to get through the entire registration process successfully.
As incentive for timely registration, ECHA is offering manufacturers, importers or only representatives a special service from ECHA’s Helpdesk. ECHA is ready to address Lead Registrants’ requests on a priority basis. When appropriate, assistance will be provided over the phone.
Registration: a Behind-the-Scenes Look
For dossiers arriving after 30 September, there will be a "floating" period -- about six months of uncertainty -- regarding the status of REACH registration. What will happen is: ECHA examines the dossier on arrival, and, if the dossier is not complete, ECHA writes to the registrant before 1 March 2011. Companies will then get a reasonable deadline (typically a further four months) to provide the information requested by ECHA. If that information is not provided satisfactorily, then the registration has failed, and there is no second chance. Failed means: the company does not receive a registration number and the substance cannot legally be manufactured or imported in the European Union – worse, any manufacturing or import since the registration deadline will have been illegal.
Submitting before the end of September will prevent companies being in an uncertain situation. Uncertain situations are risky business in today's changing regulatory landscape; it's important to have compliance details settled so a business can move forward. Please contact us for more information.
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