Why is it important?
Registration means you can stay on the market and that you will have better quality information on your substances. Gearing up for registration will help to avoid supply chain interruption through substances failing to be registered and substances becoming suddenly unavailable. This could be especially important for your customers who are Downstream Users (DUs). For example, formulators of mixtures, producers of articles, etc.
What might you have to do?
Registration will means getting active within your SIEF, determining who the Lead Registrant will be and beginning data sharing negotiations. This process can take some time so we advise that you begin this process as soon as is practicable.
If you are a downstream user or distributer, you may wish to begin probing your supply chain, enquiring as to the registration status of substances key to your business.
If you anticipate that your manufacture/import will remain beneath 1 tpa per substance, and therefore you will not have a registration duty, you may wish to update your REACH-IT account and possibly indicate that you are ‘inactive’ in the SIEF.
Regardless of your role in the supply chain, it is advisable that you know and assess your portfolio, find out if you have any registration obligations and take action as soon as possible.
Impact of EU referendum result
Based on the timescale for negotiating the UK’s exit from the EU it is our understanding that those UK-based companies affected still have the legal obligation to register their substances by the 2018 deadline.
What should I do next?
As a starting point, use the links below to find out more information. However, remember that you aren’t obliged to register. Ceasing manufacture/import or finding an alternative supplier with a valid registration are possible options. Downstream users should not assume that substances will be registered higher up their supply chain. It may be worth contacting your suppliers to see if they (or their suppliers) intend to register.
Resources
The links and information below represent selected ‘REACH 2018 relevant’ resources from the large amount of valuable information on the ECHA website. If you are looking for something specific, using terms such as ‘ECHA’ and key words in a standard internet search engine will often give good results.
- ECHA’s REACH 2018 Portal - Links for further information and useful documents.
- ECHA’s REACH 2018 Roadmap (PDF)- Portable Document Format – An introduction and framework to work around
- The REACH 2018 webinar series
- REACH 2018 - things for SMEs to think about
- Data Sharing Advice - An introduction on how to engage in data-sharing negotiations.
- Establishing Substance Sameness
- REACH exemptions - An overview of the exemptions and links to detailed guidance.
- Minimising Animal Testing for REACH – Includes information on using weight of evidence or read-across approaches to fill REACH data requirements.
- ECHA’s Annex III Inventory tool
- ECHA Q&A database
- ECHA’s Practical Guides
- ECHA - Term – explanations of the REACH jargon
Prospective registrants could also consider signing up to ECHA’s free news service.
If you need more information on ECHA’s website or IT Tools, the best place for more information is the ECHA Helpdesk. For information on understanding how to fulfil your obligations under the REACH and CLP Regulations, your national Helpdesk can help you in the first instance.