REACH Registration Enters Countdown

Which substances need to be registered before 30 November? This is the most concern of enterprises.

The twenty-third regulation of REACH regulation stipulates that the conventional substances in the EU market exceeding 1000 tons / year, more than 100 tons / year of aquatic biological toxicant, more than 1 tons / year carcinogenic (including teratogenicity, reproductive toxicity, etc.), should be registered before November 30th.

It is worth noting that some substances do not have any classification of hazards when pre registration. However, with the gradual deepening of data collection, the leading registrants define it as aquatic biological toxicity and carcinogenic substances, and the corresponding registration buffer period must also be advanced.

If the registration date is delayed, is it possible to fill in the note? The technical expert of Rui Xu said that the European Chemicals Administration (ECHA) Liaison Group announced at the end of September this year that under 5 special circumstances, it can provide the company with special help to extend the registration deadline.

These 5 situations include: failure to provide the data required by the annex VII and annex VIII on time, or the material composition and analysis data that can not be obtained from the supplier supplied, and unable to pfer the pre registration number or pre registration as a result of the change of the corporate status; the lead registrant failed to submit the complete REACH compliant dossier; the supplier within the European Union does not register the substance; the downstream user is forced to bear the obligations of the importer; because the registrant is required to adapt to the new or updated guide, it is unable to provide the annex VII and annex VIII requirements on time.

It should be noted that, if the registrant completed the registration dossier before November 30, 2010, but could not get the official registration number before the deadline, its trade with Europe could still proceed as usual.

For some companies concerned about the cost of the problem, Rui Xu technical experts, the main factors affecting registration fees are material annual production or annual export tonnage, material harm characteristics and uses, material existing data situation, enterprise scale and so on.

In the process of completing the registration by the sole representative agent, the expenses paid by the enterprise include the agent fee of the sole representative, the administrative fee charged by the European Chemicals administration and the data charged by other organizations.

Generally speaking, registration fees shall not be waiver, but in the following 3 cases, some fees can be waiving: substances are strictly controlled intermediates, tonnage is 1~10 tons / year, and all data contained in Annex VII of the REACH regulations are submitted in the registration dossier; the enterprises comply with the EU SME standards.

Some intermediate substances enterprises have submitted the issue of registration separately. For this reason, Rui Xu technical experts pointed out that it is convenient and economical to register separately, but there are also some hidden dangers. For example, the dossier may be examined by the European Chemicals authority for priority, tonnage upgrading or new use restrictions.

Enterprises should make accurate judgments about whether their products meet the strictly controlled intermediates, prepare relevant documents for examination, and formulate relevant registration submission strategies according to market expectations.

There are many laws and regulations adopted by the European Union, and many enterprises do not understand the use of these regulations. The REACH registration number has two main purposes: first, it can be used as a direct proof basis for enterprises to export to the European Union, including documents such as safety data sheets, such as registration numbers, which can be used for any occasion supervised by the EU law enforcement authorities. Two, the REACH registration number can be pmitted downwards along the supply chain to avoid duplication of roles in 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 a complete list of importers should be established after obtaining the registration number, and the tonnage coverage certificate of each importer should be set up by the sole representative of the company, so that the risk of embezzlement of the registration number can be avoided at any time. In recent years