Ever since the first REACH registration deadline of November 2010 ECHA has been doing inspections to see if registrants properly complied with the data and reporting requirements of REACH. The answer is often - NO. Recently the second report of ECHA's REACH Enforcement Forum estimated that about 20% of the companies they looked at were not in compliance. In the first report the Forum had identified 24% compliance for the earlier group of companies inspected.
Most of the non-compliance was related to failure to comply with the new Safety Data Sheet requirements or failure to correctly register their substances. Sometimes this meant no registration was submitted at all, other times there was a lack of preregistration, and in still others the company preregistered but did so incorrectly. Possible penalties for non-compliance could include loss of registrations, public shaming of companies with multiple non-compliance, fines, and criminal complaints.
The report will be available on the ECHA web site.
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