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Final REACH Registration Deadline - 31 May 2018

  • United Kingdom
  • Environment
  • Diversified industrials - Chemicals

07-09-2017

The last registration deadline for pre-registered substances manufactured or imported in low volumes (between 1-100 tonnes per year) is just around the corner.

ECHA expects that up to 70,000 registrations, for up to 25,000 substances will be prepared for 2018. The small volumes mean that many registrants are likely to be small and medium sized enterprises and as such they are likely to be inexperienced with the REACH registration process. This means that this registration deadline will be unlike any other.

Companies which have pre-registered their low-volume substances (either by the original pre-registration deadline in December 2008 or through late pre-registration) should be developing and finalising their registration dossiers, working with other members of their SIEF (Substance Information Exchange Fora) where relevant.

Any company which has not already considered its registration strategy should do so urgently. It is expected that the majority of the 2018 registrations will be single registrants and SIEFs are expected to be small or even consist of a single company. Therefore it is less likely that companies can rely on others to perform the role of lead registrant. It is also expected that less information will available for these substances. Therefore, despite the reduced data requirements for registrations below 100 tonnes per year it is expected that data will need to be generated to fill those gaps. This can be time consuming and appropriate laboratories only have limited capacity.

Lead registrants should submit their registration dossier well before the deadline, so any co-registrants also have time to meet it. Lead registrants should also be prepared for late applicants, who only become aware of their REACH registration obligation shortly before the deadline, joining their SIEF and seeking a registration.

Companies planning to manufacture/import 1 tonne or more of a new substance will need to register the substance before manufacturing/importing. The deadline for late pre-registration has now expired on 31 May 2017. For any substances which have not been pre-registered, an inquiry will need to be submitted and the substance registered before manufacturing/importing.

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