The main stages of REACH

 

REACH includes a ‘no data, no market’ principle. Manufacturers and importers have to present data and register all substances that they produce or import at volumes of one ton per year or more. ‘New’ substances that were already notified under the previous legislation will be considered as being registered and receive a registration number. After pre-registration the ‘existing’ substances (now being mentioned phase-in substances) are granted with a delayed registration period on a phased basis over a period of 11 years.

Pre-registration phase & number
The period in which substances could be pre-registered ended on November 30, 2008. Once a substance has been successfully submitted in the database, a pre-registration number will be assigned to each separate substance and legal entity combination.

There is no legal requirement to provide pre-registration numbers in the supply chain. Pre-registration numbers will not be published by AkzoNobel, nor will AkzoNobel provide these numbers on request.

Information flow
Under the new legislation the final target for information transfer to downstream users (= customers) will be the new extended Safety Data Sheet (eSDS) including the relevant exposure scenarios from the Chemical Safety Report covering all identified uses.

Communication
The formation and communication within consortia (= groups of producers/importers of a substance) is a key issue within REACH, and our long experience as an active member of chemical industry associations means that we are prepared for the procedures and tasks that will be required. This is also of great significance when the obligatory SIEFs (Substance Information Exchange Forums) are formed at the end of the pre-registration period.

Also the communication over the supply chain is a very important part of REACH. Downstream users (customers) have the duty to inform the producer on the use of a substance, or have to register their specific use themselves.