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Background on REACH Registration Deadlines
What is REACH?
REACH is the new European Union regulation concerning the Registration, Evaluation, Authorisation and Restriction of Chemicals. It came into force June 1, 2007, and replaces a number of European Directives and Regulations with a single system. A major part of REACH is the requirement for manufacturers or importers of substances to register them with a central European Chemicals Agency (ECHA). The registration will be supported by a standard set of data on that substance. The amount of data required is proportionate to the amount of substance manufactured or supplied ? the larger the quantity the more data required. If a manufacturer or importer does not register a substance, then the data on this specific substance will not be available. As a result, the manufacturer or importer will no longer be able to produce or supply it legally, i.e. no data, no market!

What next and when?
Fortunately not everything has to be done at once ? that would be impossible. The different tasks and activities will be phased in over a strict timeline that is laid out in the following table :

By Dec 2010 Registration deadline for :
  • substances supplied at ? 1000 tons per annum (tpa);
  • substances classified as Very Toxic to aquatic organisms, may cause long-term adverse effects in the aquatic environment (R50/53) at ? 100 tpa; substances classified as Category 1 or 2 CMR1 at ? 1 tpa assuming they have been pre-registered
By Jun 1, 2013 Registration deadline for substances supplied at ? 100 tpa ? assuming they have been pre-registered
By Jun 1, 2018 Registration deadline for substances supplied at ? 1 tpa ? assuming they have been pre-registered

Why are the registration deadlines important?

1. For the manufacturers/importers:
Manufacturers and importers need to submit the registration dossier for the substances they want to continue supplying before the deadline defined by the total tonnage of substances they manufacture or import.
This dossier will include a complete cradle to grave risk assessment covering all steps in the supply chain from the manufacturing of the substance to the final treatment of the waste stream and the end of life of the articles that contain the substance.

2. For the customers:
Customers will only be allowed to purchase and use materials from suppliers that have registered these substances and uses.Because the quantities that are manufactured or imported by different manufacturers can be different, the registration deadlines will not be the same for all manufacturers. Therefore, some suppliers will already have obtained a registration number while others still have a pre-registration number. Down-stream users need to inform their suppliers 12 months prior to the supplier´s registration deadline of their product uses. That way, the supplier can include the usesin his risk assessment.

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