The Problems with Waiting to File Your Joint Registration
The last phase-in deadline to register substances under REACH with the European Union is still three years away. Yet there are good reasons to start the process now, says Beth Bidstrup, director at H2 Compliance. “Our experience is that many are not as simple as they seem, so complete your joint registration as soon as you can. Don't wait until the last minute,” she says.
Companies exporting greater than one ton of substance(s) are required to submit registrations. Those that don’t will technically be out of compliance come June 1, 2018.
One report Bidstrup knows about estimates there will be another 70,000 registrations between now and the 2018 deadline. “Some companies may have one or two to do. Others may have 30 to 40 of them. They'll need to plan ahead and allocate the financial and technical resources to get them done,” she says. Although new testing isn’t required for joint registrations, companies will need to complete some analytical work for the substance identification portion of the registration. The process could take longer than companies expect.
There’s even a danger that waiting until the last minute will result in a bottleneck. “We anticipate that the sheer volume of registrations will strain existing resources both in-house and from consultants” says Bidstrup.
Knowing what ECHA looks for in a registration is also critical. Each year, the agency issues an evaluation report with illuminating statistics. “You can use it to know what key things ECHA is going to scrutinize in your dossier,” says Bidstrup. “It can help you develop a quality dossier, so that if your submission is ever evaluated, it should be an acceptable registration.”
To help companies prepare, Bidstrup will lead Preparing for 2018: Unraveling the Myths of Joint Registrations, an education session at Stewardship 2015.
She’ll talk about what is needed for a joint registration, determining the cost for a Letter of Assess; communicating with suppliers and downstream customers; and some of the legal and contractual implications. “People will walk away with a pretty good understanding of what they need to think about and how to submit a registration successfully,” she says.