The Regulation concerning the Registration, Evaluation, Authorisation and Restriction of Chemicals (REACH) entered into force on June 1, 2007. Cefic has been very active in explaining this legislation to its members, organising workshops and publishing practical guidance to understand better this extremely complex legislation. The legislation workability, which has been our priority throughout the advocacy process, remains our key focus in the learning phase following the first registrations deadline (30 November 2010).
It is important that lessons are learned from the first registration deadline, covering the highest volume chemicals. These include chemicals already identified by a specific classification triggering the registration obligations early in the process. The difficulties encountered with substances for which much information is already available should be analysed. The lessons learned should be used to facilitate the second and third registration deadlines in 2013 and 2018.
Obstacles in run-up to first registration
During the initial phase of REACH industry pre-registered more than 10 times the expected number of registrations. The unexpected influx of data, however, scuppered the smooth functioning of the “Substance Information Exchange Fora.” According to industry, progress in the SIEF was not on schedule mid 2009. The discussions on who intended to register for the first registration deadline on November 30 were hardly possible, because no IT tool was provided by the authorities. There is still no intention to provide such a tool, which risks creating even more problems for the second registration deadline in 2013 - where more SMEs and less experienced companies will play a more important role than in the first registration wave.
Other stumbling blocks were and remain substance identity, the sharing of data and costs and the jointl chemical safety reports. Beginning of 2010, the Directors’ Contact Group (DCG) between Commission, European Chemicals Agency (ECHA) and Industry Associations on meeting the REACH registration deadline was created to find practical solutions for these problems that industry faces.
Cefic has continued its activity to make REACH workable by participating in the Directors’ Contact Group. The group has identified 28 critical points in order to fulfill the registration requirements in time. Solutions were proposed, discussed and approved without postponing the registration deadline. Practical and workable solutions were found for the majority of the issues. For the others, the activity is ongoing. The situation is monitored continuously to find out whether additional activity of Cefic and/or the DCG is necessary.