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Recently, Dr. Wolfgang Rybczynski of SAP Deutschland sent me an excellent slide-deck called REACH Compliance Assessment. Unfortunately, when I uploaded the presentation to BPX, I didn’t account for the conversion to pdf. This resulted in a distortion of the message, since crucial slide notes were omitted. These slide notes explain REACH registration and pre-registration processes and timelines quite succinctly.

 

So, with due deference to Dr. Rybczynski and his colleague, Dr. Ornulf Rexin (also of SAP Deutschland), here is the relevant slide extracted from the REACH Compliance Assessment presentation, together with the accompanying notes:

 

REACH Registration Timeline

REACH Registration Timeline

 

“As you can see on this slide REACH is a multi-phase process that starts on June 1st [2008] and brings up obligations step by step.

From that point of view there is no need to panic but time you should use now to prepare consequently for REACH. The preparations should be aligned with the timeframe given by REACH.

The picture shows that, depending on the substance volume per year in metric tons and the risk potential, different timelines are given for the registration. The first registration phase ends 2010 and comprises substances with a volume of more than 1000 t/year.

Moreover, so-called CMR susbtances (those which are either carcinogenic, mutagenic or reproduction toxic) and substances classified according to the R-phrases 50 (very toxic to aquatic organisms) and 53 (may cause long-term adverse effects in the aquatic environment) need to be registered.

Substances of more than 100 t/year need to be registered by 2013; and those for more than 1 t/year by 2018.

The last two timelines require a pre-registration. Substances that are not pre-registered must be registered during the first registration phase.

The aim of pre-registration is that companies can find other companies, via the Substance Information Exchange Forum (SIEF), that want to register the same substance. According to the One Substance One Registration (OSOR) principle, companies are forced to form consortia for joint submission of substance data, avoiding unnecessary animal testing and saving test costs.

What does this timeframe means in terms of preparation of REACH?

First, you need to prepare the pre-registration. Pre-registration means that you submit: your company’s ID; together with the substance ID; plus the information on which registration phase is expected.

Pre-registration takes place (probably) between June 2008 and November 2008. Until then, you need an overview about all your substances and an idea of the volume in which they are produced or imported.

Based on this information, you can pre-register and also plan your full registration process.”

 

Further Reading

Please refer to EU REACH Pre-Registration Directives:

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