With a REACH Registration Deadline Later This Year, the EU Chemicals Agency Addresses Some Issues

This post was written by David Wagner.

In the past two weeks, the European Chemicals Agency (ECHA) has revised its online registration tool and clarified several issues, including the definition of “intermediate”.

REACH-IT, the Agency’s online registration tool, will now allow the members of a joint submission, when attempting to register their substances, to submit their dossiers as soon as the lead dossier has been accepted for processing. Under REACH, companies producing or importing the same substance must prepare a joint registration and nominate a lead registrant who will submit the registration dossier to ECHA. Prior to the change, ECHA would have had up to three months to review and process the dossier before issuing a registration number. Under the initial procedure, companies other than the lead registrant would have been unable to submit their own registration without first receiving the registration number. Now, with the change, ECHA stated that “members of a joint submission do not need to wait until the lead registrant has been informed that his dossier is complete and received the registration number before members can submit their dossiers.”

Also, based on some confusion among industry groups, ECHA restated the meaning of the term “intermediate." ECHA underlined that “an intermediate is a substance used in the manufacturing of another substance whereby the intermediate is itself transformed into that other substance” and added that “substances used in the production of articles cannot be regarded as intermediates.” Intermediates must be registered under REACH but are subject to lesser data collection and submission requirements than non-intermediate substances.

Under REACH, by November 30, 2010, registration dossiers must be submitted for substances manufactured in, or imported into, the EU in volumes of 1,000 metric tons or more per year, and for some hazardous substances at lower volumes.