Yesterday (November 30, 2010) marked the first deadline for registration of chemicals under the European Registration, Evaluation, Authorization and Restriction of Chemicals (REACH) program. And the European Chemicals Agency (ECHA) has quickly issued a press release summarizing the results - "ECHA had received 24,675 registration dossiers, submitted for nearly 3,400 phase-in substances."
A full decade in the making, the European Chemicals Agency’s long-debated Regulation on the
Registration, Evaluation and Authorization of Chemicals (REACH) reached its first deadline yesterday, requiring companies to submit registration dossiers of chemicals they wish to continue to manufacture and market.
While companies have had almost 3 years to prepare dossiers on their chemicals, most of that time was spent working with other companies in consortia and navigating the new idea of SIEFs (Substance Information Exchange Forums). According to ECHA:
"The numbers of registrations increased steadily throughout the year, but from September 2010, the trend changed. Numbers soared dramatically - incoming registrations in a single month totalled four times the number of dossiers previously registered. The increase became more gradual again in October – an increase of 7% - with statistics increasing again over the last month."
About 12% of dossiers were submitted by "Lead Registrants," i.e., the company who volunteered to present the data developed by consortia and other groups of companies manufacturing or importing the same chemicals. About 82% of the submissions were from "Member Registrants," those companies who contributed to consortium development of the dossier submitted by the Lead. Only 6% of the submissions were from individual registrants, i.e., single companies that provided all the data for a chemical.
Nearly a quarter (23%) of submissions came from one country - Germany - which shouldn't be too surprising given the number of larger firms located there. Most of the submissions (86%) came from large companies, with medium, small, and micro sized companies accounting for only 9%, 4%, and 1% of the submissions, respectively.
Only 580 of the nearly 25,000 dossiers contained testing proposals, for a total of 1,548 proposed tests. ECHA will review all of these and any test proposed on animals will be subject to public consultation.
From now any companies which have failed to register substances bought or imported over 1,000 tonnes/year with the European Chemicals Agency will be operating illegally in the European Union.
The main concerns which remain at present are about the impact on downstream users who may experience an interruption to supplies of key raw materials. ECHA is seeking solutions and started by recommending the stockpiling of chemicals. It has also has asked them to register these supplies themselves if they are imported.
The next deadline of 2013 for 100 tonnes/year or less may prove more problematical. This will bring a huge number of small-to-medium sized enterprises into the sights of Reach. These companies lack the financial resources and skilled manpower of the BASFs of this world and may struggle with compliance.
Related information
ECHA Press Memo, 01 December 2010
Related EVISA Resources EVISA Brief summary: REACH: Registration, Evaluation and Authorisation of Chemicals 
Related EVISA News November 14, 2010: Registrations pick up as REACH deadline looms September 25, 2010: The European Chemical Agency (ECHA) calls for
comments on reports proposing restrictions on mercury and phenylmercury March 10: 2010: ECHA suggests further chemicals for SVHC list October 9, 2009: REACH: Substances of very high concern June 5, 2009: EU bans certain organotin compounds September 18, 2008: REACH Update: List of 300 chemicals of very high concern June 3, 2008: European Chemicals Agency opens in Helsinkilast time modified: December 1, 2010
