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REACH Registration Rules For Promotional Products Manufacturers And Importers

Issue: 2008may

Environmental attorney Robert Matthews, whose firm has been studying REACH regulations, recently clarified the registration requirements for phase-in and non-phase-in substances under the European Commission’s guidelines.

A recent statement by the European Commission reminds companies that June 1, 2008 is the registration deadline applicable to substances that do not first go through pre-registration, according to Matthews. The Commission statement confirmed that when a full registration is submitted, the new European Chemicals Agency (ECHA) will conduct a completeness check of the registration dossier within three weeks of submission.

By highlighting this procedure, the Commission focuses the industry’s attention on the rules that apply to full registration, and prompts a reminder of which substances are subject to the June 1 registration deadline.

Under REACH regulation rules, manufacturers and importers of substances other than those that are exempt from registration—because they are manufactured or imported below the one metric-ton threshold or are regarded as registered based on a notification under Directive 67/548—must submit a complete registration dossier to the European Chemicals Agency (ECHA) by June 1 for the following:

1) Substances that do not meet any of the phase-in substance criteria under REACH Article 3 (20)—e.g., because they are not on EINECs—referred to in REACH as non-phase-in substances.

2) Substances that do meet the criteria for phase-in substances for which the manufacturer or importer does not submit a pre-registration by December 1.

For non-phase-in—i.e., “new”—substances intended to be manufactured or imported for the first time on or after June 1, companies must ensure that they first submit a complete registration dossier.

The manufacturer or importer can commence its activities if there is no contrary indication from ECHA within three weeks following submission, according to REACH Article 21. If the manufacturer or importer is not in a position to make such a submission by June 1, then it must wait until it can do so (and then wait for another three weeks) before proceeding.

The situation for companies that, for strategic reasons, do not plan to pre-register phase-in substances presents greater concerns. The European authorities take the position that such companies “should have registered their substances as of June 1, 2008 before continuing their manufacture or import” and, therefore, the period of noncompliance for manufacturing or importing a phase-in substance that is not pre-registered by December 1 would be retroactive to June 1.

Companies in this position to act to ensure that their market access is not disrupted have less than two weeks to register. Accordingly, companies intending not to pre-register phase-in substances must consider their readiness to submit a complete registration dossier by June 1. If they are unable to do so, they may need to rethink their decision not to pre-register.


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