REACH 2018 deadline, goals and recommendations
The second REACH registration deadline ended on May 31st 2013. Based on market numbers Intertek experts expect much more registrations to be performed for the REACH May 31st 2018 deadline, since all substances manufactured or imported into the EU in more than 1T/a, but not subject to the 2010 or 2013 registration deadline, have to be registered by this day. This means that workload will increase extensively for all stakeholders, especially for SMEs (Small and Medium size Enterprises).
Starting compliance efforts late could increase your businesses risk. Implementing your strategy sooner will allow:
• Management of registrations in the required timeframe
• Testing completed in time
• Avoidance of compromises to meet compliance
• Enough time for reworking the dossier following submissions with updates
In addition, Intertek recommends companies not underestimate efforts needed to manage co-registrations. It appears easy to buy a letter of access and a token from a lead registrant and submit a co-registration dossier without any data just referring to the lead-registrants’ data. However based on experience we can say that, acquisition of a letter of access can be a very burdensome and costly process, requiring contracts (SIEF agreements) to be checked, understood, accepted and legally signed, the letter of access fee to be paid and finally the joint registration to be submitted. Based on several aspects it can take easily months to get the letter of access and you may have to do this for every substance you might want to register.
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