A core area of the REACH Regulation is the registration requirement. If you, i.e. the legal entity of your company, manufacture or import more than one tonne of a substance, you are required to register this substance – but only if there are no excemptions or transitional measures. This is not always easy to decide.
If another company has already registered the substance, you must initiate contact and make a compensatory payment. It is not always easy to find a just solution for the amount. An implementing regulation has come into force to provide clarity on this matter.
If no other company has registered a substance which is essential for your business, you may have to assume the role of the Lead Registrant.
This is not an easy task. First, you need to determine whether there are other potential registrants and whether test results are already available on that substance so that you can avoid animal testing. The next steps are a data gap analysis, the implementation of necessary tests, and finally the preparation of the registration dossier. The objective is to demonstrate how the substance can be safely handled.
A small consolation: other companies that wish to register the same substance must also make a financial contribution.
If the amount of your substance subject to registration is in the range of 1–100 tonnes/year, you are still in the green zone. That is, if you have pre-registered. The final deadline for the submission of registration dossiers is 31 May 2018. This seems far away, but it really isn’t. And think of the capacity – not of your product but of the individuals required to prepare the documents. By the deadline, many other substances must be registered in parallel to yours. ⇒ Contact