REACH-SERV arrow SME Update arrow SME Note for TESS Website, 13 March 2008
SME Note for TESS Website, 13 March 2008 Print

DRAFT

Our main focus, just now, is the pre-registration phase of REACH.  

he pre-registration phase will begin on 1 June 2008 and continue through 30 November 2008, and all submissions must be made to the European Chemicals Agency in Helsinki in accordance with standard formats.  Although the format for the software has not been completely finalised, the framework is already fairly clear, and we refer to the various guidelines and guidance documents which are available, for example, on the Agency’s website at http://www.echa.eu/, through European chemicals Industry federations and associations such as the ones on our home page, and from the so-called “competent authorities” in each of the member states.  The basic software package will be IUCLID 5, which, we have to say, is rather complicated, and you may need professional help with this and in preparing your pre-registration (and later registration) documentation. 

We all know very well from our own personal experience the time and resource restraints within SMEs, and we would strongly recommend to you, if you are not already a member of one of the professional trade associations, such as indicated above, that you would join one of these groups, as we believe the technical resources available to you in this way may provide the necessary support in working through the various stages of REACH. 

Depending on your situation as manufacturer for downstream users/importer of chemical substances (or you may encompass all of these activities) you should probably by now be in contact with your customers and suppliers to confirm intention with respect to pre-registration of substances that are important to you.  We suggest you do this in writing, confirming your intention to pre-register those substances in your current manufacturing range, and/or asking your suppliers to confirm their intention to you to pre-register substances that are important to you.  Whether you choose to pre-register all substances in your current manufacturing range or not, depends on your evaluation of future business, bearing in mind future opportunities but also the possible costs of registration.  We suggest this is also a point on which you might need to take outside advice.  These is no actual fee for pre-registration, and there is no formal obligation to continue on to actual registration for a particular substance that has been pre-registered, but it is important that you pre-register, or ensure that others will pre-register, all of those substances of importance to you, asotherwise you might not be able to continue to use these substances legally after November 30.  All SMEs have a right to expect that guidelines and registration formats etc will be made available in all of the official languages of the Community, although we suppose realistically that this may take some time, and that these formats and guidance will be available initially only in the main languages of the Community.  It is fairly clear to us as SMEs in the manufacturing sector that the particular circumstances of SMEs, not least the constraints on time and resources, are not really being taken properly into account by the European Commission in working through REACH, and we realise that there are a lot of difficulties for a lot of individual companies.  Particularly for this reason, therefore, we urge that you would try to work closely with other SMEs, and with trade associations etc as indicated above and we would welcome specific enquiries to this website. 

Put in links to TESS.......??

Last Updated ( Tuesday, 18 March 2008 )
 
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