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European Law Monitor newsREACH: Industry urged to pre-register all chemicals by 1 December 2008

Some 30,000 chemicals currently in use (e.g. acids, metals, solvents, surfactants, glues) have to be pre-registered at the European Chemicals Agency (ECHA) between 1st June and 1st December 2008. As the new chemicals legislation REACH (Registration, Evaluation, Authorisation and restriction of Chemicals) will enter into operation on 1st June, the European Commission and ECHA are alerting companies of their obligations. Tens of thousands of manufacturers or importers of chemicals will have to pre-register chemicals in 2008 if they want to continue manufacturing or importing them without interruption. It has been estimated that over 180,000 pre-registration files will be submitted. The pre-registration process will enable companies to share data on their chemicals and paves the way to enhanced knowledge about chemicals. This is a prerequisite for improved safety in the years to come.

Vice-President Günter Verheugen, responsible for Enterprise and Industry policy and the Commissioner for the Environment, Stravros Dimas, commonly stated: "REACH is the most ambitious chemicals legislation in the world. It will enable us to drastically increase our knowledge on the use of chemicals and to use them safely, thus protecting human health and the environment. REACH will make an invaluable contribution to safe management of chemicals in the EU. We will soon enter the crucial stage of pre-registration, and we strongly encourage every manufacturer and importer of chemicals, to pre-register as soon as possible. To be safe, please do not miss the deadline of 1 December 2008."

Geert Dancet, Executive Director of the European Chemicals Agency, ECHA, stressed that: "The countdown towards pre-registration of chemical substances has started. ECHA has worked hard to provide guidance and tools that are easy to understand. Its multilingual website and the REACH helpdesks are ready to assist companies in pre-registering on-line."

Today's alert is driven by the concern that some companies may still not be conscious of their obligations, either because they are not aware of the scope or the specific requirements or because they believe that REACH does not affect them, especially if they are not part of the chemicals sector. The Commission therefore calls upon Member States authorities, industry, third countries and other stakeholders to help to make the obligations known to all enterprises concerned.

Who should pre-register?

All EU-based companies that manufacture in, or import chemical substances into the EU should pre-register if the quantities of the substance are one tonne or more per year.

Why should companies pre-register?

Pre-registration is needed if companies manufacturing or importing chemicals want to benefit from the extended registration deadlines which apply to most chemicals that are currently on the market. Pre-registration allows companies to submit their complete registration dossiers by 2010, 2013 or 2018, depending on the case.

Companies that do not pre-register a chemical cannot continue manufacturing or importing it after 1 December 2008 until they made a full registration with ECHA.

What is REACH?

REACH is an EU Regulation which requires manufacturers and importers of chemicals to systematically assess and manage the risks that chemicals may pose to the health and the environment. The first steps in this process are pre-registration and registration.

What are pre-registration and registration?

A pre-registration consists of the submission of basic information to the Agency: details of the company and the name of the chemical concerned (for more details see MEMO). Pre-registration is free of charge.

The pre-registration process will enable companies to share data on the chemicals they will register and so reduce costs.

Registration is an obligation on manufacturers and importers of chemicals introduced by REACH. It requires that companies consolidate data regarding the health and environmental properties and risks of their chemical and are able to demonstrate that it can be used safely. The file is then submitted to the Agency.

Registration is expected to impact some 30,000 chemicals between 1 June 2008 and 30 May 2018.

Key awareness raising activities by the European Commission and ECHA

The importance of ongoing awareness raising activities will be highlighted with a workshop to be held in Brussels on 14 April 2008 co-organised by the European Commission and ECHA. Participants will include industry and other stakeholders, Member State authorities and third countries, all of whom have important roles to play in raising REACH awareness. The workshop will be web-streamed and a recorded version will be available after the event (see link below).

The workshop will explain the key elements of the pre-registration and registration processes under REACH, focusing on practical aspects and examples. It will be followed by pre-registration awareness actions linked to the formal opening of ECHA on 3rd June 2008 and a stakeholder workshop in Helsinki this autumn.

Web-streaming information:

European Chemicals Agency website: