Companies that must register their chemicals by May 31, 2018 but that do not yet have all the test results they need for the dossier, should notify the ECHA of the situation. But an exception for such cases involves some preconditions. For example, if the data required by Annexes VII and VIII is missing, the companies must provide a justification for the delay and submit a copy of their contract with the testing laboratory – which must be dated before March 31. They must also let the ECHA know when they expect the results. You can find this information and more details in the notice issued by the Directors’ Contact Group (DCG) of the ECHA.
If the registration dossier contains all the data (physicochemical, toxicological and ecotoxicological), the document passes the completeness check. If it does not, the ECHA will grant an extension if a company provides notification before May 24, 2018.
The Stakeholders Day held in Helsinki at the end of January covered for the first time how to deal in exceptional cases. According to a report by ChemicalWatch, the announcement by the ECHA surprised participants in the meeting.
For example, Céline Coste, who is responsible for chemical registration at Solvay said that she did not know that the ECHA was to be notified of delays. She is hardly the only participant affected by the news.
Mercedes Vinas, director of dossier submission, admitted that more companies than expected will have to apply for an exception. The ECHA does not have an emergency plan for this situation. In her presentation, Vinas provided the current numbers for REACH 2018.
According to Vinas, the ECHA had received some 15,000 registrations for about 6,500 chemicals (in quantities less than 100 tons per year). 4,200 of the chemicals were registered for the first time. Some 801 companies registered a chemical for the first time in 2017, and 16% of them are small and midsize enterprises (SMEs). She also provided numbers on registrations outside the EU. Some 43% of those registrations came from importers and 28% from Only Representatives.
You can download all the presentations given at the Stakeholders Days here.
Do you have any questions about REACH 2018? If so, please contact us at email@example.com.