REACH: The Rubber Hits The Road
Preregistration Is Under Way
EU manufacturers and importers of chemicals are beginning to
feel the full impact of REACH legislation. REACH established a
"preregistration period" for chemical substances that
began on June 1, 2008 and is scheduled to close on December 1,
2008.
Preregistration applies to the "phase-in
substances," which are primarily substances that are
already present in the EU. While not mandatory, preregistration
is being pursued by most manufacturers and importers. Full
registration is a complex process that requires detailed
information about each substance, safe use guidance, testing
information and a safety report. Unless preregistered or fully
registered, covered chemicals will be functionally banned from
the EU marketplace after December 1, 2008. By preregistering,
companies can defer the ultimate registration deadline and ease
their burden of initial compliance.
Preregistration is free and primarily consists of providing
the name of all relevant substances, related identification
numbers, the expected registration deadline, the amount of each
substance manufactured or imported and contact information.
Assuming proper preregistration, the following registration
deadlines apply:
November 30, 2010 for substances manufactured or imported
in volumes exceeding 1,000 tons;
May 31, 2013 for substances between 100 and 1,000 tons;
and
May 31, 2018 for substances between 1 and 100 tons.
Guidance Documents And Annexes Updates
Several guidance documents intended to clarify key issues
have either already been issued or are currently in the works.
These documents provide guidance regarding, for example:
When and how to preregister and register substances under
REACH;
How to address chemical intermediates;
The impact of REACH on chemicals being studied for
possible development;
Specific provisions governing management of polymers and
monomers;
Rules applicable to substances in articles;
Classification and labeling of substances; and
The roles and obligations of "downstream users"
of REACH substances.
A number of Annexes to REACH including Annexes IV and V,
which identify substances that are exempt from REACH's
registration, evaluation and downstream user provisions, are
also under current revision.
First "Candidate List" In The Works
On July 1, 2008 the European Chemicals Agency first
published a provisional list of 16 substances that may be
subject to pre-market authorization (in addition to
registration). This "candidate list"...
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