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Rules & Revelations: REACH—The Cosmetic Impact

By: Carl Geffken
Posted: June 5, 2007, from the June 2007 issue of GCI Magazine.

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For most reporting companies, there is a benefit to using the pre-registration process because it will delay the date for registration and submission of a full Chemical Safety Report (CSR) beyond December 2008, or any other date imposed based upon tonnage.

Furthermore, it will allow participation in a consortium called Substance Information Exchange Forums (SIEFS), which will be created to collect and coordinate data and share the cost of required safety substantiation to satisfy concerns raised by the ECHA and required by the safety classification assigned to a given substance. The window for pre-registration is open June 1–December 1, 2008.

Pre-registration information must include the substance identity—including chemical name, CAS number, EINECS number, the anticipated deadline for actual registration, and the European registrant’s name, address and contact information. The pre-registration submission option has been strongly endorsed by industry experts close to the REACH activity, particularly because pre-registration past the six-month window is prohibited.

Once the pre-registration process has been completed, the ECHA will publish a list of the pre-registered substances, which can be used for the formation of SIEFS and the subsequent participation of companies’ representatives or chemical suppliers. For downstream users, it will be imperative to assure suppliers participation based upon chemical usage and quantity purchased. At present, it appears that the reporting company, individual or representative must be located in Europe. Alternatively, if your supplier is unable to participate in the REACH pre-registration for your ingredient, you will be obliged to negotiate or seek a new source if you intend to ship products or materials into the EU.

Registration is a more formal and demanding process, and it, too, will follow a schedule and structure based on REACH Implementation Project guidelines—also known as RIPs. Submissions will be accepted from European companies or European representatives and must include a technical dossier with the full identity of the substance, its manufacture and intended use, as well as other specific information required by the annexes.