The REACH regulations are upon us. The Pre-registration phase opened on the 1^st June and runs until the 30^th of November 2008.

Manufacturers and importers

Any business which manufactures chemicals within the EU or imports chemical substances in to the EU in quantities greater than 1 tonne per annum must register that chemical with the European Chemical Agency (ECHA). This includes substance within preparations and also substances within articles which are intentionally released.

It should be noted that if you are an importer of chemical substances from outside the EU you will need to ensure that you have the correct chemical identity of the substance or the correct names of components in preparations. This is best achieved through dialogue with your non-EU suppliers.

Users

In the meantime any business that uses chemicals in its processes must consider whether the supply of essential chemicals will be affected by these regulations. It may be possible that some chemicals will no longer be available raising the prospect of potentially serious business continuity issues. We would recommend that users open a dialogue with their suppliers if they have not already done so, and review the risks inherent in chemical supplies.

Pre-registration process

Companies who pre-register their substances can benefit from extended registration deadlines. The deadline depends on the tonnage band and the hazardous properties of the substance. The staggered deadlines are:

• 30 November 2010,
• 31 May 2013 or
• 31 May 2018

Those who do not pre register will not be eligible for the extended registration deadline and will be required to register all their qualifying substance in full on the 1st January 2009 regardless of tonnage. The pre-registration also provides an opportunity to reduce the cost of registration as the pre-register will be used to identify similar businesses which can cooperate to produce joint registrations or share substance testing data.

Pre-registration requires only limited data and there is no fee associated with it. The information needed for this phase includes:

• Substance Identity: EINECS number, CAS numbers and names of the substance
• The likely deadline and tonnage band for the substance will need to be registered; and
• The name and contact information of a Contact person or Third party Representative who will act as the contact point in data sharing