Hello and welcome to the November edition of The REACH Centre newsletter. With only two weeks left to pre-register before the 1st December deadline, the ECHA has announced that the number of pre-registrations has now topped one million. Failure to meet the pre-registration deadline means that a company cannot continue manufacturing or importing a substance until they have submitted a full registration dossier and paid the registration fee for it.

You need to take action now if you have still not pre-registered or appointed an Only Representative to pre-register for you if you are outside the EU. To find out how The REACH Centre can help, please visit our website.

On 28th October, the ECHA published the candidate list of Substances of Very High Concern. The list contains 15 substances, but more will be added when additional substances are identified as SVHC. ECHA’s Executive Director Geert Dancet said: “All companies should take note of the Candidate List. It is critical they know that the inclusion of the substances in the list generates immediate new legal obligations for the communication in the supply chain.”

The publication of the candidate list brings new duties for companies using these substances. The candidate list, and a short summary of the obligations for companies handling SVHCs, can be found on the ECHA website.

These obligations apply to the SVHCs on their own, in preparations and in articles.

Articles:

• From 28 October 2008, EU & EEA suppliers of articles which contain substances on the Candidate List in a concentration above 0.1% (w/w) must provide sufficient information, available to them, to their customers and on request to consumers within 45 days of the receipt of this request. This information must ensure safe use of the article and, as a minimum, include the name of the substance.
• From 2011, EU and EEA producers or importers of articles have to notify ECHA if their article contains a substance on the Candidate List. This obligation applies if the substance is present above 0.1% (w/w) and its quantities in the produced/imported articles are above 1 tonne in total per year per company.
  • For substances included in the Candidate List before 1 December 2010, the notifications have to be submitted not later than 1 June 2011.
  • For substances included in the Candidate List on or after 1 December 2010, the notifications have to be submitted no later than 6 months after the inclusion.

Substances:

• From 28 October 2008, EU & EEA suppliers of a substance have to provide a safety data sheet to their customers when the substance is on the Candidate List.

Preparations:

• From 28 October 2008, EU and EEA suppliers of a preparation not classified as dangerous according to Directive 1999/45/EC have to provide the recipients, at their request, with a safety data sheet if the preparation contains at least one substance on the Candidate List and its individual concentration is at least 0.1% (w/w) for non gaseous preparations and at least 0.2% by volume for gaseous preparations.

ECHA publishes an intermediate list of pre-registered substances

An Intermediate List of Pre-registered Substances has been published on the ECHA website. It contains over 50,000 substances which were pre-registered by 1 November, one month before the deadline of 1 December 2008. The purpose of the intermediate list is to give Downstream Users of chemicals a possibility to determine whether substances of interest to them are already pre-registered and, if not, for them to remind their suppliers that companies can only benefit from the extended registration deadlines (2010, 2013 or 2018) if they have pre-registered their substances by 1st December 2008. Failure to meet this deadline means that a company cannot continue manufacturing or importing the substance until they have submitted a full registration dossier and paid the registration fee.

The list is accessible via the ECHA website: click here to view the list.

By 1 January 2009, the final list required by the Regulation will be published and it will replace the intermediate list on the ECHA website. That list will cover substances pre-registered from 1 June to 1 December 2008.

REACH news in brief

• The ECHA is continuing work to improve the performance of the REACH-IT system in the run-up to the pre-registration deadline. The system had been slow to respond but the ECHA has made modifications, including removing the pre-SIEF menu and search menu until 2nd December. In spite of the higher number of concurrent users, access to REACH-IT has significantly improved.
• The ECHA has announced that if the REACH-IT system cannot cope with the large number of pre-registrations before the deadline, the agency will provide an additional pre-registration submission method in the final days of pre-registration. This method will be implemented only if absolutely necessary. The deadline for pre-registration cannot be extended by ECHA, and only a submission via REACH-IT guarantees the receipt of a pre-registration number and direct access to the pre-SIEF without delay. Therefore, companies are advised not to defer sign-up and pre-registration.

REACH statistics

• As of 21st November, the total number of pre-registrations handled by the ECHA stood at 1,469,434, far in excess of initial top-end estimates of half a million pre-registrations.
• On 1st November when the last full statistics were published by the ECHA:
  • Total number of pre-registrations: 874,288
  • Number of substances pre-registered: 51,318
  • Number of companies signed up in REACH-IT: 18,889.
  • Germany had the most companies registed in REACH-IT (3,764) and the largest number of pre-registrations (301,273). The United Kingdom had the second largest number of companies (2,808) and 244,860 pre-registrations.
  • Pre-registrations have been submitted by companies from all 27 Member States plus Iceland, Liechtenstein and Norway.

The REACH Centre holds Estonian training week

The REACH Centre has recently held a 5 day training programme introducing the foundations of REACH to representatives of the Estonian chemical industry.

Subjects covered during the course included an overview of REACH legislation and practical training on IUCLID. Further workshops on operating within SIEFs were delivered by Hammonds LLP, a leading commercial law firm with offices throughout the UK, Europe and in Asia. One day was dedicated to helping companies with their individual REACH issues and developing appropriate action plans. Experts from The REACH Centre and Lancaster Environment Centre were on hand to answer any questions the delegates had. To ensure continued support after the training The REACH Centre has provided companies with access to a secure web based support forum. Individuals can have specific questions answered and have ready access to REACH updates posted to the forum.

Hallar Meybaum, of Enterprise Estonia, said "The REACH Centre delivered an excellent and comprehensive programme to support industry in Estonia. The event provided us with a solid foundation that will underpin our future REACH activities. Many specific and complex areas of the legislation were also addressed and we now have access to the 'Estonian REACH Forum' which enables us further develop our knowledge base in Estonia."

Delegates from Enterprise Estonia with staff from The REACH Centre.

The REACH Centre can offer bespoke training programmes tailored to your organisations need. To find out more, please contact us.

Training and education surrounding REACH legislation is vitally important to ensure organisations get it right with minimal expense and upheaval. We offer a wide selection of training solutions ranging from REACH workshops through to bespoke programmes.

Working effectively in SIEFs and Consortia

Date - Thursday 15th January 2009
Venue - Lancaster University Campus
Cost - £295 per person

This workshop provides a balanced overview of the legal responsibilities and the practical business issues involved when working in SIEFs and Consortia

Read more [PDF] :: Booking form

New courses will be announced soon. You can find the latest courses listed on the training page on our website.

The REACH Centre can also provide bespoke IUCLID5 training tailored to your needs. For more information, please contact m.dallavalle@thereachcentre.com

Don’t forget The REACH Centre offers a wide range of REACH services, including pre-registration, registration, Only Representative and Third Party Representative services.