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...