Registration of Substances under the REACH Regulations
"Chemistry" Vol. 84
Tzvi Levinson, Christina Hadjidemetriou and Gil Dror, Adv.
According to the REACH regulations, every European manufacturer or importer of substances, under specific circumstances, is obliged to register the manufactured / imported substances, defined as "phase in" substances. The registration process consists of several stages, and decision should be taken accordingly, such as: 1. Is it the manufacturer's duty to register the substances, or is the obligation to be filled by the distributor? 2. What are the substances that should be registered? The registration is basically filled by supplying all the necessary data, which should be gathered in a procedure that might take time and economical and organizational resources.
In order to be prepared for the registration process, and in order to evaluate the scope of the registration obligation under REACH, it is vital to distinguish who is obliged to perform the registration, what are the criteria for registration, what is the necessary scope for each organization, and what is the time frame for registration for each substance according to its characteristics. By knowing the time frame and its conditions, pre – registration and time frame extension is possible.
The above issues are dealt in this article.