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Reminder: Window to Pre-Register Chemicals under REACH is Closing

U.S. manufacturers that export chemicals to Europe, take note: You have until Dec. 1, 2008, to pre-register your chemicals with the European Chemicals Agency (ECHA) under REACH (Registration, Evaluation, Authorisation & Restriction of Chemicals), a major reform of European chemicals policy, affecting all global supply chains that produce and use chemicals.

Although REACH came into effect on June 1, 2007, the first major milestone for business began June 1, 2008--the beginning of a six-month window when chemical manufacturers can pre-register their products. Pre-registration is a very simple process that can be done online, ECHA notes. The agency adds, however, that if companies miss the pre-registration window, they will not benefit from extended registration deadlines and will have to go through the much more involved, and costly, "registration" process straightaway in order to export chemicals to Europe.

Recently, ECHA published on its Web site an intermediate list of almost 40,000 chemicals that were pre-registered by Oct. 1, 2008--two months before the deadline. This intermediate list was not foreseen in the REACH Regulation, but it was published at the request of industry. By Jan. 1, 2009, the final list required by the regulation will be published on the site, replacing this intermediate list. The final list will cover substances pre-registered from June 1 to Dec. 1, 2008.

The purpose of the intermediate list is to give downstream users of chemicals a chance to determine whether chemicals of their interest are already pre-registered, and, if not, for them to remind their manufacturers and importers that companies can only benefit from the extended registration deadlines (2010, 2013, or 2018) if they have pre-registered their chemicals by Dec. 1, 2008. Failure to meet this deadline means that a company cannot continue manufacturing or importing the chemical until it has submitted a full registration and paid the registration fee.

The intermediate list contains the EC/CAS number and name of 37,768 pre-registered chemicals. In addition, information such as the first envisaged registration deadline, the number of related chemicals that may be used for (Q)SAR grouping (category approach) and read-across are included, along with the chemicals' synonyms. ECHA said that when it has doubts about the validity of a submitted pre-registration, the company concerned was contacted to clarify its pre-registration. The chemicals identified in such pre-registrations may not yet appear on the intermediate list, the agency noted. For more information, visit http://apps.echa.europa.eu/preregistered/pre-registered-sub.aspx.

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