1. Registration deadline has passed, what now?
Jan HOLOMEK, ReachSpektrum
Chemicals Management Forum 2018
October, 1, 2018

2. REACH General remarks Transitional arrangements
In force from 2007
Transitional arrangements
Preregistration
3 registration deadlines – 2010, 2013, 2018
Authorisation of SVHC substance
Restrictions
Enough time to comply with obligations

3. Registration deadline 2018

4. REACH Registration 2018

5. REACH Registration 2018

6. What next? Registrations are NOT closed
New substances > 1 tonne/year
All companies can submit registration of their (new) substances
Inquiry process applies before registration
INTERMEDIATES under SCC (Art. 17/18), SCC must be demonstrated
Substance ID supported by chemical analysis
Assessed by ECHA
Assignment to the “right” group of co-registrants by ECHA
Registration must be achieved BEFORE production/marketing the substance.
Before 2018 – substance might have been marketed based on pre-registration

7. What next? Registrations are NOT FINAL
Existing substances > 1 tonne/year
Must be already registered
Registration dossiers are being checked for compliance by ECHA
ECHA Decisions
Substance ID
Further information requests – more testing
Precision of information in current dossier
Discussions/teleconference/meeting with ECHA possible in some cases
If deadline not met or request not fulfilled = cancelling the registration

8. What next? Dossier quality
Industry made HUGE effort and invested millions/billions? EUR to comply with information requirements under REACH registration
Industry is still committed to respond to ECHA decisions but wish to stay reasonable
Still, ECHA finds the quality of dossier “not meeting ECHA expectations”
ECHA evolves/increases criteria for dossier compliance

9. What next? SIEF SIEFs exist no more
Replaced by Joint Submissions or groups of companies “wandering in the space of pre-registration”
SIEF agreements must be revised/ended
Rules of Joint Submission operation must be agreed within members and Lead Registrant
Cost sharing and reimbursement must be adjusted
New registrants agenda…

10. Future issues (as seen by me)
Operating costs disputes
For running the Joint Submission/REACH Consortia
For updating dossier (REACH obligation)
Relevance and acceptability of costs
Example: CONCAWE spent around EUR for updating the dossier for one substance
Data sharing disputes
ECHA provides registrant in Joint Submission with endpoint, based on proof of payment
Data holder (Lead Registrant) is not satisfied with the amount and raise court action

11. Future issues (as seen by me)
Competitiveness or survival of European chemistry?
Small businesses are severely affected by REACH costs and WILL remove a number of diverse substances from the market
Opening for non-EU entities with strong funding
Switch of enforcement from national Inspections to Customs
Adaptation to new regulatory trends
Nanoforms
Circular economy = longer life cycle
Waste reduction = more substances
Recycling REACH issues = SVHC in plastics
Ban of substances/products by restrictions

12. Thank you.