10 years after the start of REACH the last REACH registration deadline expired on 31 May 2018. Since 2008 no less than 13,000 European companies have collectively registered a total of almost 22,000 substances with the European Chemicals Agency (ECHA). This does not imply that the obligation to register has expired after 31 May 2018. From today the REACH registration of chemical substances must have been completed before the said substances, or products that contain the said substances, can be placed on the European market. No data, no market!
What is REACH?
REACH stands for Registration, Evaluation, Authorisation and Restriction of Chemicals. This is a Regulation of the European Union, adopted to better protect human health and the environment against risks that chemical substances can bring about and to improve the competitiveness of the chemical industry in the EU.
Obligation to register or not?
Do you manufacture chemical substances for personal use or for delivery to others? Do you import chemical substances or products that release chemical substances from outside the EU? Then you are probably subject to a number of important responsibilities on the basis of REACH. Whether you are held to register a substance with the ECHA depends on, inter alia, the following factors:
- Your role in the supply chain;
- The volume of the produced or imported substance;
- The scope of application and potential exceptions.
Complex registration process
Once it is clear that you are subject to a REACH obligation to register then it is important to determine what substances you must and what substances you want to register. This can be done on the basis of a REACH substances administration in which you keep track of the volumes of the substances produced or imported by you. You only proceed with a registration on your own or with fellow registrants. The registration must ultimately be prepared and submitted in IUCLID format. Also after approval of the registration is must permanently be kept up to date.
Keeping a REACH substances administration has become even more important since 31 May 2018. Only through this administration can it be signalled in a timely fashion whether you must register a substance in order that you can continue producing or importing it. Précon Quality Services can support you, inter alia, in the preparation of a substances administration, the creation of analyses of the total volumes and the registration process with the ECHA, in order that your products are compliant.