REACH regulation registration countdown

From the first registration deadline date of the REACH Regulation (EU Chemicals Registration, Assessment, Licensing and Restriction Regulations) - November 30, 2010, less than one month is left. How can we take advantage of the effective time to complete the registration? Under what circumstances can companies postpone registration? On November 2, experts from Rui Xu Technology Co., Ltd., a subsidiary of the China REACH Solution Center, were interviewed by reporters and answered questions on these hot issues.

Which substances need to be registered before November 30? This is the issue that companies are most concerned about. Article 23 of the REACH Regulation provides for the release of more than 1,000 tons/year of conventional substances, more than 100 tons/year of aquatic bio-toxic substances, and more than 1 ton/year of carcinogenic (including teratogenic and reproductive toxicity) substances in the EU market. Registration should be completed by November 30th. It is worth noting that some substances do not have related hazard classification when they are pre-registered, but as data collection progresses, the leading registrant defines it as aquatic biological toxicity and carcinogenic substances, and its corresponding registration buffer period must also be advanced. .

If you delay the registration date, can you "recharge"? Rui Xu technical experts, the European Chemicals Agency (ECHA) Directors Liaison Group announced at the end of September this year, in five special circumstances, can provide companies with special help after the deadline for registration. These five cases include: Failure to provide the data required by Annexes VII and VIII of the Regulations or the availability of material and analytical data in the mixture provided by the supplier on time; failing to transfer the pre-registration number or pre-registration after submission due to changes in corporate identity The lead registrant failed to submit a complete REACH compliance dossier; suppliers in the European Union did not register the substance, and downstream users were forced to assume the importer’s obligations; due to the registrant’s need to adapt to new or updated guidelines, it was not timely Provide the data required by Annexes VII and VIII of the Regulations.

It should be noted that if the registrant completes the registration of the registration file before November 30, 2010, but cannot obtain the official registration number before the deadline, his trade with the EU can still proceed as usual.

For some enterprises concerned about the cost, Rui Xu technical experts, the main factors affecting the registration fee are the annual production of materials or annual export tonnage, material hazard characteristics and uses, material existing data, the size of the company. In the process of entrusting the sole representative agent to complete the registration, the fees paid by the company include the agency fee, which is the sole representative, the administrative fees charged by the European Chemicals Agency, and the data fees charged by other organizations. In general, the registration fee may not be reduced or exempted, but in the following three cases, part of the cost can be reduced or exempted: the substance is a strictly controlled intermediate; the tonnage is 1 to 10 tons/year, and the REACH Regulation Annex VII is filed in the registration file. All data included; companies meet EU SME standards.

Some intermediate material companies have submitted separate registration questions. In this regard, technical experts from Rui Xu pointed out that although it is economical and convenient to submit individual registrations, there are also hidden dangers. For example, dossiers may be subject to priority review by the European Chemical Agency, tonnage upgrading, or New use restrictions and more. Enterprises should make accurate judgments on whether their products comply with strict controllable intermediates, and prepare relevant documents for investigation, and formulate relevant registration submission strategies according to market expectations.

Due to the many regulations introduced by the European Union in recent years, many companies do not understand the use of these regulations. Rui Xu technical experts, REACH registration number has two main purposes: First, can be used as a direct proof of the company's export to the EU, including registration with the safety data sheet and other documents, can be used for any EU regulatory authorities. The second is that the REACH registration number can be passed down the supply chain to avoid duplicate registration of roles on the same supply chain. In addition, in order to ensure the long-term validity of the registration number, Rui Xu technical experts also reminded enterprises that after obtaining the registration number, a complete list of importers should be established, and a tonnage coverage certificate should be issued to each importer by the sole representative of the commission. The risk of misappropriation of registration numbers by other companies can be circumvented at any time.