This post was written by David Wagner.
At this week’s Fifth Stakeholders’ Day, which was broadcast over the web, the European Chemicals Agency (ECHA) reported that a little less than half of the substance registrations – about 2,000 – have been submitted in advance of REACH's November 30, 2010 deadline. As we’ve discussed on the blog, the European Union’s REACH law requires about 5,000 substances produced in or imported into the European Union to be registered with the ECHA by November 30 or their supply on the EU market will be illegal. Next month’s deadline applies to substances produced in or imported in annual volumes of 1,000 metric tons or more, and to volumes of one metric ton or more of the most hazardous classes of substances that are carcinogenic, mutagenic, or toxic to reproduction.
At the October 4 event, ECHA stated that it expects about 3,000 substances to fall into the high volume category, and between 1,500 and 2,000 to fall into the lower volume hazardous categories. They also reported that the ECHA had received over 4,000 dossiers addressing over 2,000 substances and compared these numbers to an expected total of 38,000 dossiers covering almost 5,000 substances. Recall that, under REACH, companies producing the same substance are required to work together in a Substance Information Exchange Forum (SIEF) and share data. ECHA expects a lot more dossiers than substance registrations because once the lead registrant of a SIEF submits a dossier, other companies manufacturing or importing the same substance must submit supplementary dossiers.
ECHA also reported that, to allow companies to check on the status of substance registrations, they will publish a list of registered substances by the end of October, and update that list weekly. When it’s available, we’ll publish a link to the ECHA’s list on our blog.
Another REACH news item from the event was the ECHA’s expectation to add 40 more substances to its candidate list of “Substances of Very High Concern” in 2011. The candidate list is the list of hazardous chemicals that could be restricted or banned under REACH, and 40 additional substances would double the size of the current list.
CLP Notifications Not as Impressive
Regarding upcoming requirements under another EU law, the Regulation on the Classification, Labeling and Packaging of Substances and Mixtures (CLP Regulation), ECHA officials indicated that efforts to comply were not as robust. The CLP Regulation requires, by January 3, 2011, companies that manufacture, import, use, or distribute chemical substances or mixtures to notify the ECHA about the classifications of and labels for any substance or mixture, regardless of its annual tonnage, before they place it on the European Union’s market.
On the CLP notifications, the ECHA reported that they expect to receive a few million notifications and had received about 300,000 to date. Not surprisingly, the ECHA encouraged manufacturers and importers to submit CLP notifications as soon as possible, and not rely on being able to piggyback with existing CLP notifications submitted by other companies, which is permitted only by the REACH registration system.