REACH - The European Chemicals Regulation which requires the registration of chemicals manufactured or imported into the EEA in quantities of over 1 tonne per year, unless exempt. The final registration deadline captures chemicals manufactured or imported between 1-100 tonnes per year. Quantities exceeding 100 tonnes should already have been registered by previous deadlines.
The final REACH registration deadline may seem a long way away. However, the European Chemicals Agency’s (ECHA) recent REACH 2018 Roadmap provides a timely reminder to companies of the significant amount of work, time and cost involved in registering a substance.
It is estimated that companies will make 70,000 new registrations in order to meet this deadline. This is three times more than the previous two deadlines (in 2010 and 2013). Some companies may have to register hundreds of chemicals. ECHA also expects that many more small and medium sized companies (SMEs) will be affected, potentially registering substances for the first time.
To date the complexity of the REACH legislation has challenged many manufacturers, importers and users of chemicals. Registration requires the submission of a significant amount of data relating to the substance. A key principle of REACH is that tests involving vertebrate animals are not repeated and instead data on the same/a similar substance is shared. This typically results in competitors being required to share information with each other, potentially resulting in disputes.
Despite the reduced data requirements for lower tonnages, it is still expected that costly and time-consuming data will need to be generated and then shared. ECHA has promised new guidance to help companies navigate through the challenging REACH landscape, and to address gaps in the current guidance.
As a starting point companies should assess whether and how the 2018 REACH registration deadline affects them. In order to do this information on the products companies place on the market is needed.
The 2018 deadline will complete the data gathering process on substances in the European market resulting in the most comprehensive chemicals database in the world, much of it publicly available. It remains to be seen whether industry’s efforts and costs in its production will be worthwhile.