REACH and (pre-)registration in a nutshell
Everything you always wanted to know about (pre)registration - but were afraid to ask...
Preregistration
REACH (Registration, Evaluation, Authorization and restriction of CHemicals) is the new european chemicals regulation that affects all manufacturers, importers, suppliers and downstream users of chemicals.
In case REACH affects you, you should have preregistered the compounds you use before December 1st, 2008.
That means you're too late now, but you can still ask for help what to do next.
What is (was) PREregistration actually?
Preregistration is, or actually was, nothing but letting "Europe" know which chemicals you are using, or intend to use.
Preregistering chemicals was free and relatively easy. The pre-registration period, however, already ended on November 30th, 2008.
It would have been better to pre-register your substances, so that they gained phase-in status and could benefit from the phased introduction of the full requirements of REACH.
The ECHA (European CHemicals Agency) in Helsinki issued a clear preregistration leaflet.
You can also still read a folder with some practical steps for preregistration and a (recent) list with many Frequently Asked Questions about REACH.
If you want the real stuff: here is the complete Regulation (1.8 MB), with the corrigenda (also 1.8 MB).
Together 1127 pages, so PLEASE DON'T PRINT THEM! Let's save some trees...
Even though the preregistration period is over, you can still contact us about what to do next.
WHY should I have preregistered?
To put it briefly: to prevent big trouble!
In the worst case you will not be able to use certain compounds as of December 1st, 2008. ("No DATA, no MARKET!")
In other cases the eventual registration will cost you significantly more time, and money, than if you had preregistered in time.
WHO should (pre-)register?
All companies and organisations that deal with large amounts of compounds should decide whether they have to (pre-)register them or not.
It does NOT only affect the manufacturers of (base) chemicals, but also many other kinds of industry, as well as companies that import and distribute chemicals, mixtures and products.
What ROLE do I have?
The following roles are relevant for (pre-)registration:
- Manufacturer - produces compounds, products within the European Union
- Importer - imports compounds, products from outside the European Union
- Downstream user - uses chemicals to produce products, articles
- Distributor - wholesale, retail
- Only Representative - may carry out REACH obligations for non-EU manufacturers
- Data holder - holds data on compounds relevant to ECHA
Of course one company can have more than one role at the time.
Most of the downstream users (DUs) and distributors will probably not have to (pre-)register any compounds themselves.
They DO, however, need to check if their suppliers (upstream) meet their obligations under REACH!
On the other hand, suppliers (manufacturers and importers) also need to inform their downstream users about the steps they have taken to meet these obligations.
To check what role(s) your company has you can use several tools, like the Navigator at EChA.
If you are still in doubt, you may contact your business association, or the local Chamber of Commerce, or just contact us.
And spread the word! Many recent studies have shown that a lot of companies are still not (fully) aware of their obligations under REACH.
Which CHEMICALS, compounds are involved?
A very good question indeed. There is no easy solution, each case has to be judged separately.
But in a nutshell: all compounds (chemicals) that are manufactured in or imported into the EU in quantities of 1 tonne or more per registrant per year.
There are many exemptions to this rule, like substances occuring in nature (ores, crude oil), and substances that already fall under other regulations, like medicines.
On the other hand, Substances of Very High Concern (SVHCs) may be subject to authorization even if used, produced or important in (much) lower quantities.
Look here for a more detailed overview.
What about MIXTURES, articles and products?
Every mixture of compounds and each product (article) needs to be checked on the chemical composition.
In the case of products it is especially relevant if they contain compounds which are intended to be released from the product.
What is the PRICE of all this?
The registration of substances will eventually be quite expensive, it may cost thousands of euros for each compound. The preregistration of substances at ECHA was free, however.
Preregistration was not an obligation; it is a right, provided by ECHA, to make it possible for companies to benefit from the extended registration deadlines for phase-in substances. To stimulate the use of this right, pre-registration was free.
Of course delegating the (pre)registration process to a specialized consultant will cost you something.
Here, at www.preregistreer.nl, we will stil be able to conduct you through the registration process, whether you preregistered or not. So please contact us in order to get more information.
Will our data be SAFE?
Naturally! We will regard your data with ultimate discretion.
In case you don't want other parties to know anything about the compounds you want to (pre)register we can act as a third party representative. From January, 2009 all data for each preregistered compound will be gathered and presented by ECHA so SIEFs (Substance Information Exchange Forums) can be formed, as well as the consortia where parties can work together. Of course you will be able to count on our help in these processes as well.
Please contact us now.
Filling in the form will cost you less than a minute.
