Today - December 1 - marks the start of a new era in European chemical manufacture. From now any companies which have failed to register substances bought or imported over 1,000 tonnes/year with the European Chemicals Agency will be operating illegally in the European Union.
In the build-up to this deadline there had been many, many predictions of failure by those seeking to comply: many were worried about the operation Substance Information Exchange Forums - the groups set up by manufacturers of the same chemical. Others feared a repeat of ECHA's IT meltdown which plagued the pre-registration period.
But interviews I conducted last week with Europe's trade group Cefic and ECHA painted a different picture of a relatively smooth lead-up to the deadline. And statements put out today by the UK's ReachReady, Cefic, and ECHA reinforce this mood. French Rhodia, BASF and even Russia's Lukoil have all said how smoothly it has gone in recent days.
Could all the fuss have been just a worried industry whipped up into a frenzy by the media? This has echoes of the Millennium bug which turned out to be something of a non-event. We will have to wait now to see if there is any fallout over the next few weeks.
The main concerns which remain at present are about the impact on downstream users who may experience an interruption to supplies of key raw materials. ECHA is seeking solutions and started by recommending the stockpiling of chemicals. It has also has asked them to register these supplies themselves if they are imported.
The next deadline of 2013 for 100 tonnes/year or less may prove more problematical. This will bring a huge number of small-to-medium sized enterprises into the sights of Reach. These companies lack the financial resources and skilled manpower of the BASFs of this world and may struggle with compliance.