Just three months to go! It’s the final countdown to REACH registration of chemical substances in lower volumes 1-100 ton/year. The preparation of a lead dossier should have started latest June 2017 but now the European Chemicals Agency (ECHA) offers the possibility for latecomers Lead Registrants to notify the Agency that they have booked the required laboratory analysis until 31 March 2018 so that the registration dossier can be accepted. But a late decision increases the risk of missing the 31 May 2018 deadline and staying out of the EU market after 1 June 2018.
For Co-registrants that need to buy a Letter of Access (LoA) time is also running out.
The latest statistics from ECHA show that until January 2018 only around 4000 of the expected 25000 substances have been registered for the 31 May 2018 registration deadline. So, in total it is unknown the situation for around 20000 substances for which no company has taken yet the role of lead registrant to prepare the complete registration dossier.
During a recent conference in Helsinki the ECHA informed that the number of number of registered substances remains low, most registrations are for already registered substances in previous years, the majority of submissions came from outside Europe via Only Representatives and the percentage of SMEs registering is lower than expected.
• Will my suppliers register all my substances? Will they still be available for purchase after 1 June 2018? Will my uses be covered?
• May I need to register as an Importer for those chemicals sourced outside the EU?
• Are my formulations going to be affected? May I need to replace some substances in my mixtures?