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Less than 12 months left to comply with EU chemicals legislation
Published:  13 July, 2017

The UK Chemicals Stakeholder Forum has published new guidance documents for registrants, downstream users and article producers in how to comply with the REACH 2018 deadline.

The Registration, Evaluation, Authorisation and Restriction of Chemicals legislation controls the manufacture, import and use of chemicals within the European Union and European Economic Area.

Its main purpose is to ensure that industry is responsible for the safe use of chemicals throughout the supply chain, contributing to a high level of protection of human health and the environment, and to facilitate the free circulation of chemical substances within the internal. The body responsible for the administration of this legislation is the European Chemicals Agency.

The last deadline to register low-volume chemicals is 31 May 2018 and ECHA is recommending that companies start preparations immediately.

The deadline applies to substances which are manufactured or imported into Europe annually in volumes between 1 and 100 tonnes.

If substances falling within the 1-100 tonne per annum range are not registered by the 2018 deadline, their supply could cease.

UKCSF’s updated guidance has been compiled to assist companies to submit dossiers to ECHA. It is also aimed at downstream users who need to assess the potential for disruption of their supply chains if substances which they depend on are not registered.

The guidance consists of a generic note covering what SMEs need to know about the REACH registration deadline including flow charts to illustrate and explain the relevant processes; a self-assessment guide for SMEs which are downstream users of low volume chemical substances; and a self-assessment questionnaire for SMEs who manufacture or import articles.

Among the subjects covered are Substance Information Exchange Forums; information requirements for the two tonnage bands of 1-10 tonnes and 10-100 tonnes; costs of registration and how these are shared; and what happens if the registration deadline is missed.

ECHA has estimated that the likely number of registration dossiers for the 2018 deadline will be greater than the combined number of dossiers submitted for the corresponding 2010 and 2013 registration deadlines for higher tonnage substances. Moreover, ECHA is also expecting a significantly higher number of small and medium-sized companies to be involved in the process, compared with the previous deadlines.

The documents can be found on the UKCSF website (https://www.gov.uk/government/groups/uk-chemicals-stakeholder-forum) under the ‘Publications’ section and under the heading ‘Updated forum guidance for SMEs and downstream users on REACH 2018 registration deadline, with an explanatory note’.