The REACH-regulations have been effective since June 1st, 2007 and begin with a notice period (12 months).
Until
the REACH regulations come into full effect the previous regulations
for registration will apply according to chemical law, i.e. during the
12 months notice period.
For you as a potential nominator,
however, it will be important during this period to prepare
an exact overview of the chemical substances you have to deal
with: what kind and quantity of substances you manufacture?
- what kind of substances you buy within the European Union and
- will the suppliers of these substances continue to produce or import?
- what kind of substances you buy in countries outside of the European Union and
- will these suppliers register their substances under REACH or
- will you become responsible yourself for this registration?
At the end of this notice period you should be certain, what kind of substances you have to pre-register,
because the pre-registration phase begins immediately thereafter.
June
1st, 2008 (6 months) (the pre-registration phase begins).
Pre-registration means that you have to announce to the agency in
Helsinki the names of all substances to be registered with suitable
tags e.g. the CAS number, your address and/or name and address of a
selected person, who will represent you in relation to the agency and
the intended period of the registration. Finally the volume in which
you bring these materials into circulation should be notified. If
you want to make reference in the full registration procedure to test
reports of similar substances, you must indicate also these substances
at this time.
December 1st, 2008 (the end of the pre-registration phase).
Eighteen
months after the entry into force of REACH, thus 6 months after
beginning of the pre-registration you should have pre-registered all
substances, for which you carry the responsibility of registration.
Within the next month the agency will publish on the Internet a list of
those substances, which have been pre-registered. January 1st, 2009 (beginning of information exchange).
One of the goals of pre-registration is, that manufacturers
or importers of identical substances may come together in order to exchange and share certain information. This
should happen in an SIEF, an information exchange forum, which is formed for each substance, for which there
exists more than one potential nominator.
This means that after pre-registration obligations have been met you should contact other manufacturers and importers,
in order to prepare the exchange of existing data (in particular those concerning vertebrate animal effects). |