October 21, 2019 by Sylwia Kosmala-Grzechnik
Although the REACH registration deadline for phase-in substances passed in May 2018, it is not a closed topic for many companies.
The European Commission has recently published Regulation (EU) 2019/1692 which clarifies the rules on registration and data-sharing for phase-in substances after the final registration deadline for phase-in substances. 31st December 2019 has been set as the cut-off date after which some conditions specified in the REACH Regulation ((EC) No 1907/2006) for phase-in substances will no longer apply.
This will have the following implications that any company who have registered or plan to register a phase-in substance need to be aware of:
- After 31st December 2019, pre-registrations will no longer be valid. An inquiry dossier will need to be submitted prior to registration to obtain information from ECHA on other registrants and to begin data-sharing negotiations. The additional time required for preparation and acceptance of an inquiry dossier should be factored into any future planning.
- In order to maintain fairness between new and existing registrants, if you manufacture or import a phase-in substance at low volumes (between 1 -10 tonnes per year), you may still be eligible for registration with a reduced dataset (Annex VII physicochemical properties only) if the substance does not meet the criteria listed in Annex III of REACH.
- From 1 January 2020, all registrants will need to calculate their manufacture or import tonnage per calendar year. Any changes in tonnage band as a result of this will require an update to the registration dossier.
- From 1st June 2018, Substance Information Exchange Fora (SIEFs) ceased to exist. However, ECHA continue to encourage companies to share data as required by REACH and to use communication platforms similar to SIEFs in order to facilitate the data sharing process. It is clear that REACH did not end with the final phase-in registration deadline and continued communication between registrants will be vital to co-ordinate dossier updates.
wca can help you to meet your obligations under REACH so please contact us if you need further information or need assistance.