The REACH Advisory Group of the VCH is reminding its member firms not to push preparations for the registration required in May 2018 to the back burner and to address the matter right now. Two-and-a-half years is not a lot of time, given the complex preparatory tasks that companies must master when dealing with a registration. One of the time-consuming tasks they must address is coordination with third-country producers. The following questions must be clarified:
- Who is responsible for the registration?
- Who is the principal processor of specific tasks?
- What data is relevant?
- What data might be missing, and which tests are still outstanding?
Ultimately, the tests might make all the difference. Companies must remember that the closer the first deadline approaches, the longer the waiting lists at the required laboratories will be.
Caution is also required when, according to Article 8 of the REACH Regulation, the importer does not perform the registration, but a sole representative does for a third-country producer. The sole representative is then the registrant according to the REACH Regulation. The companies involved are well advised to examine the genuineness of the sole representative. If such representatives do not meet their obligations or are simply unavailable at the end of the process, the importer bear the risk not to have acted within the law.
The guidelines (available only in German) provided by the German REACH-CLP Biocide Help Desk of the Federal Authorities are helpful. The German Federal Institute for Occupational Safety and Health (BAuA) is also offering an informational event primarily aimed at companies that have little experience with the registration process. It will be held from 10:00 a.m. to 4:00 p.m. on November 2015 in the office of the BAuA in Dortmund. The cost is €70.
At KFT, we are thoroughly familiar with REACH, have helped shape processes, and have developed solutions. For more than 10 years, we have offered the widest-possible variety of services related to REACH. If you have questions, we are ready to help at any time with our expertise. Please contact us as firstname.lastname@example.org.