This page is aimed at the education and enlightenment of those of us lucky enough to be dealing with REACH!
We will post relevant and practical articles on REACH implementation for the public to read and digest. If you would like to contribute to this page or have something interesting (and practical) to say about REACH, please get in touch via our online form or by email.
Separate registrations required for each company an OR represents.
The European Commission has announced that Only Representatives appointed to register substances on behalf of non-EU manufacturers will have to submit separate registrations for each company they represent.
The Commission has conceded that it was wrong in its earlier interpretation, which required Only Representatives to submit one registration aggregating tonnages for all the non-EU manufacturers it represents.
This is good news for non-EU exporters who were concerned that the previous Commission interpretation would mean that their substance registration deadline would be brought forward due to the bulking together of registrations.
H2 Compliance and the Redstone Group US Partnership.
H2 Compliance and the Redstone Group have announced the establishment of a partnership for the provision of REACH services in the United States. This will allow US clients to benefit from local REACH expertise in the US from a leading regulatory firm while also having a footprint in the EU for Only Representative services through H2 Compliance.
H2 Compliance and Lee International Partnership Korean Partnership.
H2 Compliance and Lee International IP and Law Firm in Korea announce a partnership to deliver REACH-related services to the Korean market.
Countdown to pre-registration.
The clock is ticking. Manufacturers and Importers must pre-register their substances by the 1st of December 2008 in order to avail of the extended registration deadlines under REACH. How ready is your business?
Businesses should be currently be planning for the work involved in preparing for pre-registration and communication within the supply chain. Our advice is to push the responsibility for registration up the supply chain where possible. This may not be possible in all instances, therefore you will need a 'Plan B'.
Plan B involves getting your hands dirty and filtering through your substance inventory to analyse which substances fall within the registration thresholds. It is also important to identify the substances that are critical to your business in order to determine where a loss of supply could impact severely on production.
A not-often known fact is the requirement for the submission of similar substance identification information for pre-registration. Similar substance identification is also known as Quantitiative Structure-Activity Relationship or QSAR. It is based on the assumption that similar molecules have similar effects (not always true -lookup the SAR paradox!).
The basis for submitting QSAR is to ensure that all substances are identified according to their individial properties, for instance Sulphuric Acid has 3 SIEF's because there are various types of Sulpuric Acid, each with small differences in structure and activity.
If you need advice or help (we also offer QSAR services) - don't be afraid, pick up the phone and start a dialogue. We are happy to help!