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No analytical data, no registration

20 April 2018

As we all know, the final REACH deadline of the 31stMay is fast approaching. After this date, unless the substance is registered all manufacturing or importing of substances in volumes greater than 1 metric ton per year must cease.

As part of the registration, substance identity testing must be completed to ensure that the substance matches the existing registration. The testing must be completed to a high standard and reported in a manner that is acceptable to ECHA which means that a full methodology and set of interpreted results must be provided for each required analytical method and all constituents/impurities must be identified and quantified wherever possible when present at 1%. ReFaC has a number of contacts in multiple testing facilities which are able to meet these standards for both organic and inorganic substances.

As the deadline draws closer, reputable testing facilities are becoming busier and busier, with testing slots being booked up. Recently ReFaC have noticed that the estimated completion time for substance identity testing has increased from an average of 4 weeks up to an average of 6 weeks. In some cases, testing facilities may not be able to return reports until after May 2018. With the deadline being just 7 weeks away, it is imperative that decisions are made quickly as to whether or not you will be submitting a registration.

If you do not hold a valid pre-registration for the substance, the inquiry route must be taken in order to registered the substance. In this process, the potential registrant must submit an inquiry dossier to ECHA for review. This dossier contains the substance identity testing as well as other information. ECHA’s review process has been known to take around 11 weeks for a decision to be communicated but this time may increase further once all registrations have to be submitted in this way. It is ReFaC’s understanding that after 31st May pre-registrations will not be considered valid and all registrations will therefore have to be conducted via the inquiry route. This could add a further 11 weeks (or longer) until imports/manufacture can restart after 1 metric ton has been reached.

ReFaC urges all clients and potential clients to assess which substances in their catalogue require registration immediately. Action should be taken without any further delay in order to minimise the potential disruptions to your business.

For assistance with this, please contact ReFaC now.

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