Manufacturers and importers must pre-register their substances by 31 May this year to meet the 2018 REACH registration deadline exactly one year later, ECHA reminded delegates at the Echa Stakeholders’ Day in Helsinki.
This year is “crucial” for those pre-registering substances in volumes between one and 100 tonnes. “If you start next year, you may really miss the boat.” Pre-registering is “the only way to get immediate access” to substance information exchange forums (Siefs).
If companies do not do this by the deadline, they will need to submit an inquiry to Echa to register before they can enter the market. Preparing an inquiry using Iuclid will take more time than pre-registering through REACH-IT, require more information and take Echa longer to process.
Meanwhile, Cefic REACH director Erwin Annys noted, alongside authorities, is “surprised” to see that many pre-registrations are still coming in. “The extremely high number in 2008 made us think that they should be much lower [for 2018].” A high number of importers or only representatives are submitting them “to be on the safe side”, he said.
Cefic has advised downstream industry associations that if their members are uncertain whether a substance needs to be registered, they can still continue to act as an importer and complete the late pre-registration.
Echa has so far received only around 8,000 dossiers for the last registration deadline – about a seventh or eighth of what it is expecting, Christel Musset, Echa’s director of registration, told the audience in Helsinki.
The agency plans to conduct a survey before the summer to collect information on companies’ registration intentions, she told delegates.
PPORD
There is the option to use the product and process orientated research and development (PPORD) exemption, but ECHA warned that this is more complicated and so “we encourage you to pre-register by 31 May”.
Ms Musset pointed out that, for certain types of substances, it is possible to get a five-year exemption from registration by using PPORD, but that companies, especially small ones, “are not fully aware of this”.
Mr Dancet said they can contact their relevant industry associations to raise issues for discussion in the REACH Directors’ Contact Group, which will be re-established soon. Originally created in 2010 by the European Commission to resolve challenges related to the first registration deadline, the group, which includes representatives from Echa, the Commission and industry bodies, will do the same for the latest deadline.
Use information requests
The deadline for use identification requests is also 31 May 2018 – where downstream users make their use of a substance known to the chemical supplier in order to ‘cover it’ for continued use in the registration. This is something few downstream users are aware of.
Echa said, it is “very difficult to implement in practice” due to the complexity of supply chains; the need to provide sufficient information when making a use known; and the fact that registrants may decide not to include the use in the chemical safety assessment (CSA) for business reasons.
Because of this, said the agency, manufacturers and downstream users have said they prefer not to promote this deadline as it may trigger “unwanted one-to-one communication”. Instead, the recommended way forward is use maps.