REACH-SERV arrow SME Update arrow TESS SME website note august 2008
TESS SME website note august 2008 Print

Pre-Registration/Intermediates Pre-Registration is now in progress, and you should check carefully if you need to pre-register any substances, or that others are doing this on your behalf. 

If you are making or using (or importing) chemical substances in quantities greater than 1MT/year, preregistration is strongly recommended, except for certain well-defined exemption categories. 

If you have not already done so, you should list or tabulate all chemical substances manufactured and/or used on your site by: 

  • Substance name 
  • The quantity used 
  • Whether you manufacture/purchase for your own use from a supplier located within the EU/purchase from a supplier who imports this from outside the EU 
  • Any other information your possess in relation to the substance, particular hazards etc 

Information and guidelines on submitting pre-registration files are available on the website at the European Chemicals Agency at http://echa.europa.eu, and you should be able to get help and advice from industry colleagues, trade and professional organisations and from a number of organisations offering pre-paid services.  If you are not a manufacturer you will want to make contact with your supplier, and confirm that they will be arranging any necessary pre-registrations, and for detailed product information and for whatever more information you may require. 

If the substances you are manufacturing or using can be classed as intermediates, which are defined as substances which are entirely transformed by chemical change during the specific application in which they are used, theREACH regulation (Articles 17-18) provides for a reduced burden of registration under certain conditions.  Essentially, you need to be able to demonstrate that your manufacture or usage is well managed, corresponding to the concept of “rigorous control”, in order to avail of the reduced notification regime.  You should, therefore, review your operations in detail to ensure you can comply with the concept of “rigorous control” and you should refer to the guidelines published by the European Chemicals Agency (ECHA), which are available on their website, Guidance  for Intermediates, update  february 2008.  The European Fine Chemicals Group (EFCG), a sectoral group within Cefic, the European chemical industry federation, is developing an initiative, based on a risk assessment approach, and this may be helpful to you.  An introductory note explaining the EFCG approach will be available shortly on the TESS website. You may be able to get help and advice from colleagues in industry, and from trade and professional organisations, and you can contact EFCG at http://www.efcg.cefic.org/ 

Last Updated ( Thursday, 04 September 2008 )
 
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