ERJ staff report (DS)
Helsinki, Finland -- EChA, the European Chemicals Agency charged with implementing REACH (Registration, Evaluation, Authorisation and restriction of CHemicals) legislation said companies facing exceptional situations that are likely to prevent them from registering on time should inform ECHA well ahead of the deadline of 30 November 2010.
In five specific scenarios, the Directors' Contact Group has agreed that ECHA can offer help either by relying on its discretionary rights under REACH or by providing companies a transparent means to demonstrate good faith. Every affected company will need to submit a web-form as far ahead of the deadline as possible, providing detailed justification of its situation and an explanation of the measures that it has taken to comply with its obligations under REACH. Upon receiving this information, ECHA will provide instructions as to how to submit a registration by the deadline.
The five scenarios are:
- Difficulties to provide data required in Annex VII and Annex VIII in due time or difficulties for importers of mixtures to obtain compositional and analytical data of the substances in the mixture from their suppliers (Issue No. 10).
- Impossibility of transferring pre-registrations or submitting a late pre-registration due to legal entity changes (Issue No. 15).
- Failure by the lead registrant to submit a fully REACH compliant dossier (Issue No. 20).
- Downstream users are obliged to become importers, as a substance is not registered by any EU based supplier (Issue No. 21).
- Registrants need to accommodate new/updated guidance and hence have difficulties to provide data in Annex VII and Annex VIII in due time (Issue No. 10).
- The situations in which ECHA can recognise cases of exceptional hardship of registrants providing sufficient justification of their individual situation are further enumerated in a Notice that can be accessed via a new DCG web section on the ECHA website (see links below)
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Press release from EChA
Directors' Contact Group (DCG) on EChA website