Helsinki - The European Chemicals Agency, ECHA, which is overseeing implementation of the European Union's REACH chemical regulation, has issued a warning to companies to only pre-register substances they will go on to register fully.
ECHA said producers should reflect on their strategy before pre-registering substance(s). it has already received 352 641 pre-registration, and says some of these are not valid.
Companies wishing to have some of their pre-registrations deleted should send a request by registered mail to ECHA.
ECHA said REACH-IT requires producers to declare that the substances they pre-register are phase-in substances within the meaning of Article 3 (20) of the REACH Regulation.
'Only Representatives' are also reminded that, according to Article 8 of REACH, they can only be appointed by a person outside the community who manufactures a substance, formulates a preparation or produces an article that is imported into the community, and that the documents showing this must be available.
Certain pre-registrations ECHA has received are in breach of these articles and the companies involved are liable to penalties, ECHA said.
And, ECHA added, two companies have attempted to pre-register the entire EC inventory - a practice which the agency said, mildly, "should not be followed as it is not in accordance with the aim of pre-registration which is designed for data sharing in advance of the registration."
Such a practice negates the usefulness of the list of preregistered substances, ECHA indicated, saying that a company doing it will find participation in the Substance Information Exchange Fora (SIEFs) unmanageable.
It is particularly disadvantageous for downstream users, who should be able to notify ECHA of their interest in a substance not appearing on the list of pre-registered substances.
Another problem with some of the pre-registrations received are that the name of the substance does not refer to any chemical name that could be used for the purposes of a SIEF.
Where ECHA has doubts on the validity of a submitted pre-registration, it is contacting companies to clarify this.
Companies wishing to have a preregistration deleted can send their request by registered mail to: ECHA, Directorate C / Pre-registration Team, Annankatu 18, 00121 Helsinki, Finland.