ECHA offers support to registrants in exceptional cases
Companies facing exceptional situations that are likely to prevent them from registering on time should inform ECHA well ahead of the deadline of 31 May 2013.
Helsinki, 1 March 2013 – At the first registration deadline in 2010, the Directors' Contact Group (DCG) including the European Commission, ECHA and six participating European industry organisations identified exceptional scenarios where registrants may, through no fault of their own, find themselves in difficulty submitting a full registration dossier by the registration deadline.
ECHA is again offering help for companies affected by four scenarios identified by the DCG where companies face similar difficulties regarding the upcoming registration deadline of 31 May 2013. ECHA does so either by relying on its discretionary rights under REACH or by providing companies with a transparent means to demonstrate good faith.
The DCG has identified the following instances where such pressing and exceptional circumstances could apply:
- Difficulties in providing data required in Annex VII and Annex VIII in due time or difficulties for importers of mixtures to obtain compositional and analytical data of the substances in the mixture from their suppliers (Issue No. 10).
- Impossibility of submitting a late pre-registration due to legal entity changes (Issue No. 15).
- Failure by the lead registrant to submit a fully REACH compliant dossier (Issue No. 20).
- Downstream users being obliged to become importers, as a substance is not registered by any EU-based supplier (Issue No. 21).
The conditions under which the solutions apply are described on the DCG section of the ECHA website. This section also contains a Summary Paper outlining the solutions established by the DCG as well as a Notice outlining the prerequisite information that companies will need to submit, and the consequneces they may expect. The DCG web section also describes how an affected registrant should contact ECHA.
Every affected company will need to contact ECHA as far ahead of the deadline as possible, providing detailed justification of its situation and an explanation of the measures that it has taken to comply with its obligations under REACH. Upon receiving this information, ECHA can provide instructions on how to submit a registration by the deadline.