Countdown for REACHThe 31 May 2018 deadline appears to be a problematic one and many fear consequences for the tanning industry due to the impossibility of finding commonly used substances for which registration was not required and which have, therefore, been removed from the market.
The third and perhaps most problematic Reach deadline is only a few months away. By May 31, 2018 all substances produced or imported in the EU in quantities ranging from 1 to 100 tons a year will have to be registered. Since the REACH regulation is based on the “no data, no market” principle, if businesses do not register the substances with ECHA (European Chemicals Agency) by 31 May 2018, they will no longer be able to produce them, import them or use them. Because of the low tonnage, it is feared that this deadline will have an impact especially on small and medium-sized chemical tanning businesses. Indeed, it must be reminded that from 1 June 2018 as far as non-registered substances are concerned, unless they have been exempted from registration (that is to say, produced/imported quantities under 1 ton a year), it will no longer be possible to market them, and therefore nor use them to produce items, except for the disposal of the quantities bought before that date.
It is a well-known that many substances will not be registered because of the high expected costs and, since there is no obligation to inform clients, according to many experts it is likely that the withdrawal from the market will take place without notice, with obvious difficulties in finding adequate alternatives. This latest deadline of the European regulation on the use of the chemical substances used in the European manufacturing industry could therefore give rise to heavy consequences for the Italian tannery sector. For its part, ECHA has made an exceptional effort to help those businesses that will be required to register by the end of May, for the first time, the substances they produce or import. In December 2017, 17.000 substances were registered, and it is assumed that another 25.000 will be registered by that deadline.
The Agency has dedicated a specific section of its site exclusively to the registration deadline of 31May 2018. The registration process has been simplified in 7 stages:
1. know the company’s portfolio;
2. find co-registrants;
3. organize the activities with the co-registrants;
4. assess the risks and hazards of the substances;
5. prepare the registration dossier;
6. submit the dossier;
7. keep the registration up to date.
Furthermore, for each of these stages ECHA’s site provides specific references to the technical support guides as well as useful advice based on the experience with previous registrations.