Next REACH Deadline: Small is Big
The next major REACH registration deadline concerns substances manufactured in or imported into Europe in relatively small quantities, just 1 to 100 tonnes per year. ECHA is encouraging companies to prepare now for registration in those ranges. Low volumes represent a big compliance challenge because many small to mid-sized businesses fall into the category of businesses who use or ship chemicals in that range.
November 3, 2014 Boston, Mass, USA Actio Corporation today announced to the manufacturing community that ECHA, the European Chemicals Agency, is urging all companies to start preparing now for the next REACH registration deadline. This key deadline concerns substances manufactured or imported into the EU in relatively low volumes, 1 to 100 tonnes per year.
Know thy inventory
If you manufacture chemical substances or import them from outside the EU above one tonne per year, you may have registration obligations under REACH. Additionally, if you manufacture or import a product (mixture, article), it may contain substances that need to be registered individually.
If you have pre-registered substances that you manufacture or import from outside the EU above one tonne but not more than 100 tonnes per year and have not already registered them, the REACH registration deadline of May 31, 2018 concerns you.
If you haven’t yet pre-registered your substance, it’s not necessarily a handicap. Late pre-registration may still be an option until May 31, 2017.
The pre-registration period occurred between June 1st and 1 December 1st, 2008. It allowed potential registrants of the same phase-in substance to get together and submit a registration dossier jointly. Pre-registration was a requisite to benefit from the extended registration deadlines foreseen for these substances.
Potential registrants who, for the first time after December 1, 2008, manufacture or import a phase-in substance in quantities of one tonne per year or more can still submit certain information to ECHA (late pre-registration) and benefit from the extended deadlines. Producers and importers of articles with an intended release of a substance can also submit a late pre-registration.
Late pre-registrations have to be submitted within six months after the manufacturing or importing of the substance that exceeds the one-tonne threshold and no later than twelve months before the relevant registration deadline. Therefore, the late pre-registration period ends on May 31, 2012 for substances to be registered by May 31, 2013, and May 31, 2017 for substances to be registered by May 31, 2018.
Late pre-registration is only obligatory if companies want to benefit from the extended registration deadlines. Companies can also decide to register their phase-in substances immediately, but you must first submit an inquiry.
As far as a SIEF goes, after pre-registration and subsequent discussions on the sameness of the substance, the company becomes a member of a Substance Information Exchange Forum (SIEF).
Find out more about substance identity on the ECHA web site.
ECHA now publishes a Registry of Intended Chemicals, which might be SVHCs later: Registry of intentions.
Download the current REACH Candidate List of Substances of Very High Concern: The REACH list of chemicals.
About Actio Corporation
For over 15 years, Actio has delivered enterprise compliance platforms to the world’s manufacturers and their suppliers. Actio technology provides on-demand, centralized materials and risk management— down to the chemical-substance level for automated compliance with REACH, RoHS, conflict minerals, GHs requirements and more. Companies using Actio can quickly adapt to ever-changing global market conditions and standards. Actio’s product line includes solutions such as “Material Disclosure,” a complete enterprise compliance platform.
Chris Nowak, Director, Business Development
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