2018 will be the year of the SME’s in terms of REACH, as it is expected that the major of co-registrants and lead registrants will be small & medium companies. But not only will the type of registrants be a big differentiator in the last REACH registration deadline. The lack of information on the substances and resources in-house are seen as significant challenges by the 2018 REACH registrants, especially when ECHA expects to receive up to 70 000 registrations representing up to 25 000 substances.
Affected by the REACH 2018 deadline?
Companies manufacturing or importing substances in the EU ( on their own, in mixtures or present in articles) between 1-100 t/year, are required to REACH register their substances by the 31st of May, 2018. If your company belongs to this group, then you will need to prepare a join dossier for each substance and submit this information via REACH-IT, to the European Chemicals Agency (ECHA) by the required deadline.
Pre-registration, still possible?
Companies planning to pre-register substances with volumes below 100t/year, please keep in mind that late pre-registration may still be possible until the 31st of May, 2017.
Substances without lead registrant?
For companies aiming to take the lead role, REACHLaw can provide you with a multi-disciplinary team with expertise and background from various areas, such as chemistry, toxicology, environmental science, economy, regulatory and finance.
Furthermore, we will take care of all the lead tasks as an example: data mining and information collection, IUCLID dataset population, hazard assessment of chemicals, exposure assessment for human health and environment, Sief communication, drafting of the agreements and many more, to make sure that your lead dossier will be submitted with at least two months before the last REACH registration deadline, to give co-registrants enough time to submit their own registration dossiers.
Are you first time registrant?
Don’t know where to start or would like to to out-task the whole REACH registration project or parts thereof?
We can assist you as your Only Representative or as your service provider, with your registrations as co-registrant or as lead registrant. We have vast experience in taking companies through the different phases of the registration process including SIEF and Consortium. We provide resources and expertise for the hazard assessment, exposure assessment and risk characterization when needed. We provide customers with a complete chemical safety report and necessary collection of information in the supply chain, handling of third party access rights to complete the technical dossier and submit it to ECHA.
Non-EU manufacturer?
Companies located outside the EU need to appoint an Only Representative (OR) in Europe in order to be able to REACH register their substances. Having and OR relieves EU companies importing the substances, within the same supply chain, from any registration obligations, as they will be regarded as downstream users according to the requirements of the REACH regulation.
Our Only Representative service allows non-EU companies to take part in the REACH registration process. As OR, we will carry out all the pre-registration and registration work needed to successfully submit your dossier to ECHA. In addition, we provide a long term legal presence and client representation as well as carrying out all the mandatory continuous data collection tasks as company size as required by the REACH regulation.
Interested?
Would you like to receive a REACH proposal or sign up for a free 30-minute consultation to discuss further your case?
Contact us