The authority is currently analysing which firms will need to comply with the REACH deadline through a number of different approaches. These include ‘top-down analyses’ of pre-registrations and other information, and asking firms directly about their intentions to register.
It has also established a REACH registration 2018 sub-group of its advisory Chemicals Stakeholder Forum. This will take a ‘bottom-up’ approach in consulting trade associations and firms directly on their views on a number of issues. Specifically, it is asking British firms and those with supply chains in the UK that may be affected to respond to the following questions:
- which are the vulnerable sectors/ products/ substances/ substance groups that you are already aware of?
- what is the best way of identifying any other vulnerable downstream sectors/ products/ substances/ substance groups that might present a supply chain risk but are currently unknown?
- what actions and support activities would be most helpful from the competent authority, including steps to help ensure the minimisation of animal testing?
- how might your organisation, or others, work with the competent authority to reach those downstream of pre-registrant companies to gather further intelligence? and
- are there any immediate practical ideas or suggestions you would want the UK competent authority and/or Echa to consider that would help you with the 2018 REACH registration deadline?