REACH: what will happen nowPaola Ulivi of Danger & Safety Paola Ulivi is a safety expert in the chemical-tanning sector, one of the most […]

Aug 02, 2018
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paola-ulivi
Paola Ulivi of Danger & Safety

Paola Ulivi is a safety expert in the chemical-tanning sector, one of the most appreciated consultants in this field. We asked her about the most frequently questions asked by the operators in the last period.

There are many questions but the most frequent ones obviously concern the near feature.

What happens if a company intends to produce or import over one ton of a substance?

In reality there is not much change compared to before. The 31 May only set forth the end of a transitional period that companies, which had pre-registered the substances according to various tonnage bands, could benefit from. From now on it is sufficient to be aware that registration is necessary before producing or importing. For now it is still possible to register using the pre-registration number, if any. Otherwise, an inquiry dossier should be presented as necessary for non-phase-in substances. We will see if a subsequent regulation will make changes to this effect.

What should I do if, after 31 May, the supplier has not yet notified me the registration number and the extended safety data sheet?

As previously mentioned, the deadline of May 31 is just the end of a transitional period. It will of course take some time before all the information is available. Many registration numbers will be attributed over the next few months, although the dossiers have been submitted on time. We need to be patient and wait for the system to be fully operational.

Can substances produced or imported before 31 May be marketed after this date?

Yes, ECHA has specified several times that substances produced or imported before expiry can be marketed provided that the date of their production or import is clearly documented”.

According to your experience, has the chemical-tanning sector prepared itself for this deadline?

To tell the truth, I can not say that the sector has prepared itself in time. In the last 2-3 months and even in May I have received dozens of requests for the registration of substances. The problem is that the chemical-tanning sector mainly consists of small and medium-sized companies for which the economic commitment required by REACH has proved to be very burdensome. This fear has led to the companie’s stalling to see which substances the market demanded most, given the economic situation in recent years. But this also means that for many substances no dossier has been prepared and the result is clearly evidenced by the registration statistics (only about 20,000 registered substances).

The May 31 deadline is experienced with some anxiety by the chemical-tanning sector. There are those who fear a general price increase, some who believe certain substances will be unavailable and others who dread are great confusion. Are all these fears founded according to you?

On the basis of the above considerations, it is obvious that there is an anxiety on the sector’s part. There will for sure be a cost redistribution incurred for supply chain registrations (price increase) and, at the moment, a disappearance from the market of unregistered substances. But what I want to reiterate is that May 31 should only be seen as the starting point. Registration does not have an absolute time frame and can continue from now on, perhaps with more awareness.

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