25 November 2010 17:30 [Source: ICIS news]
By Nigel Davis
From 1 December 2010, the "no registration no market" rule applies to all chemicals sold in volumes greater than 1,000 tonnes/year and highly toxic and persistent substances. It will be possible to sell non-registered chemicals from existing stocks in the EU after the deadline but it will not be possible to manufacture or import them until a registration is made.
Registration applies to legal entities selling chemicals on the EU market.
Suppliers have known about the deadline for years but it remains to be seen whether the vast majority are up to speed with Reach. If they are not, there is the prospect of the sort of supply disruption that parts of the manufacturing industry fear.
Chemical industry players at this stage appear relatively sanguine. The major companies are in full Reach compliance. The work has been done to collect health and safety data for the chemicals they sell that are subject to this registration deadline. Around the time of the registration deadline - 30 November - the robustness of the European Chemicals Agency’s (ECHA’s) IT systems will become apparent.
There are likely to be between 25,000 and 30,000 individual registrations of around 3,000 substances, the European chemicals trade federation Cefic told ICIS on Thursday. That is a somewhat lower number of substance registrations than expected earlier due to overlaps discovered within the substance information exchange forums (SIEFs) set up to facilitate the Reach registration process.
ECHA data on Thursday showed that 15,367 substance dossiers had been registered to date. Running up to the deadline the ECHA says it is ensuring that registrations can be made even if its Reach-IT system is unavailable, for whatever reason.
The costly and time-consuming process is exercising a great many industry minds. BASF has had some 250 personnel working on this registration phase of Reach, according to a spokeswoman.
The company is registering 600 chemicals in this first phase Reach registration. It expects to register close to 4,000 substances by the third registration deadline which is in 2018.
BASF reckons Reach that compliance to 2018, including data processing, fees and experimental work, will cost it between €500m ($665m) and €550m.
Despite the apparent air of calm, a rush to the registration deadline is still expected.
“A lot of people are working very hard to get things done on time, Jo Lloyd, director of the UK-based advisory service REACHReady said.
The number of lead substances registered so far is just under 2,500 so it is still not fully clear what the total number might be, she suggested.
This phase will include the registration of between 1,000 and 1,500 highly toxic, persistent, carcinogenic or mutagenic substances. The number of these "substances of very high concern" (SVHCs) that might be registered is not clear given that some may be withdrawn from the market.
There are on-going legal proceedings concerning the registration, evaluation and authorisation of one, acrylamide. It is mainly used in polymers used in food packaging, largely as an intermediate that would be exempted under Reach. Producers assert that there is insufficient evidence to identify the chemical as a SVHC.
Lloyd says that there are still a number of widely used and well-known bulk chemicals, although not necessarily petrochemicals, which have yet to be registered. That suggests that there will be a rush of registrations up to the deadline.
If the deadline is missed, non-registered suppliers or importers will have to meet customer demand from stock and may face a delay of three months before the ECHA can accept a registration.
“Get your registration in even if it is imperfect,” Lloyd suggests. “You can update it later.”
She believes that the registration process will go “right up to the wire”.
($1 = €0.75)
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