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Additional info for REACH 2007 : Brussels, Belgium, 17-19 April 2007

Sample text

Companies who manufacture or import these substances can take advantage of longer registration deadlines by going through a “pre-registration” process. This must be done individually, and each company must pre-register with the Agency during a 6-month period between June and December 2008. Once they have done this, a company will then have much longer to compile the technical dossiers required for full registration. The precise date for registration of phase-in substances depends upon the tonnage band and hazard associated with that substance (substances used in greater volumes or considered more hazardous are to be registered first).

As a minimum the words ‘safer’ and ‘alternative’ need clear definitions. Definition of ‘Safer’ In the context of substitution, a ‘safer’ substance is one that can be shown to have a substantially lower risk overall than the one to which it is being compared. Substitution by an alternative substance should also not lead to any materially important reduction in sustainability. Definition of ‘Alternative’ A substance that is capable of providing a level of performance that is acceptable to the regulator, the user, (and the consumer if relevant) at a cost that is not prohibitive and whose supply is adequately assured.

Given the significant possible penalties that companies may face great care will therefore be needed to ensure competition-compliance both as regards the actual substantive data itself and also as regards the conduct of parties within consortia when discussing issues concerning the technical data. Practical guidance There are a number of steps a company can be taking when considering SIEF/consortia membership. Companies will want to put in place a consortia agreement to govern the terms of membership.

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