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December 2007 Update Print

Pre-Registration 

We are now looking ahead to the pre-registration phase which begins in june 2008. As many of us will be manufacturers of substances , but also purchasers or importers, in effect “ downstream users”, both aspects need to be considered. We suggest you would begin now to write to your suppliers asking them to confirm their intention to pre-register the substances you purchase from them for your particular application. If you manufacture, you can expect to receive letters from your customers asking you to confirm your plans in this regard. Bear in mind that the consequences of missing the pre-registration phase could be expensive! Detailed advice can be got from your national trade association, or competent authority, or european groups such as Cefic 

Intermediates 

There is a lesser burden of registration for intermediates, subject to guidelines issued by the EC in june 2007, which define concepts such as “ rigorous control”. We are optimistic that a pragmatic approach to monitoring and managing this aspect of REACH will be adopted by the authoritis, but would welcome any questions or comments on this topic which could be addressed to...... 

Fees

The EC has published a framework proposal for fees and charges for REACH which will cause grave concern for SMEs and lead to substantially higher costs than we were given to believe earlier. You should address your comments directly to the government agency in your own country responsible for REACH, or to the Directorate General for Enterprise ( DG 5) in the european commission.

Last Updated ( Monday, 11 February 2008 )
 
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