Wednesday, September 29, 2010

ECHA to use its "discretionary right" to support REACH chemical registrants that can't meet the November 30th deadline

Well, within limits.  As the November 30, 2010 deadline rapidly approaches, the European Chemicals Agency (ECHA) is anticipating that at least some (or perhaps many) companies will be unable to complete their REACH registration packages for REACH by the time.  In a September 27th press release, ECHA says:
Companies facing exceptional situations that are likely to prevent them from registering on time should inform ECHA well ahead of the deadline of 30 November 2010.
However, this support will only be available in "exceptional cases," specifically under five scenarios:

  • Difficulties to provide data required in Annex VII and Annex VIII in due time or difficulties for importers of mixtures to obtain compositional and analytical data of the substances in the mixture from their suppliers (Issue No. 10)
  • Impossibility of transferring pre-registrations or submitting a late pre-registration due to legal entity changes (Issue No. 15)
  • Failure by the lead registrant to submit a fully REACH compliant dossier (Issue No. 20)
  • Downstream users are obliged to become importers, as a substance is not registered by any EU based supplier (Issue No. 21)
  • Registrants need to accommodate new/updated guidance and hence have difficulties to provide data in Annex VII and Annex VIII in due time (Issue No. 10)   

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