May 31st, 2012
All phase-in substances, manufactured or imported in the EU above 100 tonnes per year, must be registered by 31st May, 2013.
Work needs to have started if companies are to fulfil all obligations required for registration. As many companies learned in 2010, failure to prepare in plenty of time leads to rushed and needlessly stressful submissions, and is more likely to result in potentially costly dossier rejections. All companies involved in the 2013 round of registrations should, ideally, have set the ball rolling already, and those that haven’t should not delay any longer.
Lead Registrant deadline
Last October we provided a suggested timeline for successful submission. Companies should, by now, have shared all relevant data, or commissioned new testing, and the preparation of the IUCLID files and Chemical Safety Assessments/Reports (CSA/Rs) should be well under way.
The amount of time required to produce a CSA/CSR should not be underestimated, and Lead Registrants need to remember that other SIEF members cannot submit their dossiers until the Lead Registrant dossier has been accepted for processing. The ECHA suggested deadline for Lead Registrant dossiers is 31st March, 2013 at the latest – just 10 months from now!
Letter of Access
In some instances purchase of a letter of access will be sufficient to allow you to register. REACH is based on the principles of data sharing, and if a dossier for the same substance was submitted in 2010, registration in 2013 can be completed by buying a letter of access (LoA) from the relevant SIEF Lead Registrant. We provided an outline for this process last October.
Our role in your registration
Here at wca environment we have extensive experience in all aspects of REACH registration, and can support you through the entire registration process with our suite of REACH services, which include:
- Literature searches
- Data gap analysis and development of test strategies
- Data review and interpretation
- Preparation of IUCLID dossiers
- Hazard assessment and PBT/vPvB assessment
- PNEC and DNEL derivation
- Evaluation and application of in silico alternative methods (QSAR and read-across)
- Classification and labelling
- Exposure assessments
- CSR preparation
- Dossier submission
- Strategic advice on cost-effective approaches to Registration
We were involved in hundreds of successfully submitted dossiers in 2010, and are ready to provide companies with the same high standard of service for the 2013 deadline.
Remember, companies that don’t register the substance they manufacture or import on time cannot place it on the EU market.