The European Chemicals Agency (ECHA) recently launched a campaign to remind industry to start preparing for the second REACH registration deadline, as reported by REACHspot. We put together a few guidelines on how to prepare for the next round of REACH regulation deadlines. Really, the next one to worry about is May of 2012. Here’s what you need to know.
The big REACH deadline in 2013.To prepare for the REACH 2013 deadline, companies manufacturing or importing chemicals in Europe — in quantities at or above 100 tonnes per year — are required to register such substances with ECHA by May 31, 2013.
But first, find out if your substances are already registered. To do this, simply go to the ECHA database of registered substances and search for your chemical.
If your substance meets the criteria of passing through the EU at a quantity of 100 tonnes or above and it has not already been registered, you are required to register your substance.
How to compile information to register. There are a few elements involved in compiling necessary information for registration.
- Substance identification and sameness of substance: confirm with the other preregistrants that you have the same substance
- Hazard information: collect all data available on the intrinsic properties of the substance to be registered
- Data sharing: as part of a joint registration, gather and share existing information, consider alternatives to testing and answer any information request from within your Substance Information Exchange Forum or SIEF
- Chemical safety assessment: carry out a chemical safety assessment in order to produce a chemical safety report based on the hazard information collected and knowledge on the uses
To wit: for joint submissions, there must be a so-called Lead Registrant who, yes, leads — and Members who follow. The Lead Registrant is one registrant acting with the agreement of the other assenting registrant(s) who will submit the joint registration dossier with all information. ECHA recommends this is done at least 2 months before the legal deadline, which means by March 31, 2013. Members are other registrants who have confirmed their membership in the Joint Submission in REACH-IT, they have to submit their registration after the Lead Registrant within the May 31, 2013 deadline.
REACH deadlines 2012.There are 2 key deadlines for May of next year.
- Late preregistration deadline prior to the 2013 registration deadline, for first time manufacturers and importers. Late preregistration is a simple process. You just submit your information, via an agent, your own internal REACH software, or online using REACH-IT. Please note that late preregistration is only allowed under specific circumstances.
- Downstream users should notify suppliers of uses by May 31, 2012 at the latest.
You are a downstream user if you use a substance, either on its own or in a mixture — also called a chemical cocktail — in the course of your industrial or professional activities. If you are a manufacturer or an importer of a substance, a distributor or a consumer, you are not a downstream user. Guidance is available.
Also, it’s advised that you research available tools for substance management and REACH management in particular, try a Google search for REACH software to start.