The third REACH Registration of chemicals deadline will be Friday May 31st 2018. This follows on from the first and second REACH Registration deadlines in 2010 and 2013, respectively. In 2010 and 2013, REACH deadlines were for chemicals manufactured within the EU or else imported into the EU in quantities greater than 1000 metric Tonnes Per Annum (TPA) or quantities greater than 100 TPA, respectively.

There are now over 6500 chemicals REACH Registered since REACH was written into EU law in 2006. When one considers the resources that companies around the world have employed over the last 3-5 years (and possibly longer), to achieve these registrations, it is truly exceptional.

At the final REACH registration deadline in 2018, it is estimated that over 70,000 chemicals will be registered with ECHA. When one considers this number versus the number of chemicals that are registered today, approximately 64,000 chemicals are yet to be registered. Put another way, this is ten times the number of chemicals that need to be registered compared to those which are registered. While the information requirements and the complexity of the dossiers will be lighter compared to the dossiers required for the previous deadlines and while some substances may not be registered for economic reasons, there are still an enormous number of dossiers to prepare.

Unlike the higher tonnage bands, it is more likely that there will be several companies with the same substance whose tonnage exceeds 1 TPA.  The preparation of the dossiers will technically be achievable; however, companies need to consider the logistical aspects of this task.  Completing outstanding testing will become progressively more difficult as we approach the deadline.  Completion of SIEF engagements and identification of SIEF Leads will lead to significant bottlenecks as well as identification of available technical data and agreement on classification and labelling will all lead to significant delays making 2018 the most challenging deadline yet.

H2 Compliance are working with companies today with 2018 in mind to ensure on-time registration of substances.  For some companies, the number of substances is in the 100’s, for others there are multiples of  10’s.  H2 Compliance is working to minimise the impact of these registration requirements through our Dossier Modus Registration Service.  Please contact us if you would like to discuss our approach to dossier completion for 2018 – 2018 is not that far away!