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Deadlines loom for chemical users and late pre-registrants

Downstream users of chemicals have less than two months to notify their suppliers how they make use of their substance. Information on both the use and the conditions under which the substance is used should be communicated in writing to suppliers, although the 30th November deadline only applies to those substances with a registration deadline of 1st December 2010.
 
Substances that will require registration by 2010 are:
  • Those manufactured / imported in quantities >1000 tonnes per year
  • Those manufactured / imported in quantities >1 tonne per year that are classified as carcinogenic, mutagenic or being toxic to reproduction
  • Those manufactured / imported in quantities >100 tonnes per year that are classified as very toxic to aquatic organisms or which may cause long term adverse effects in the aquatic environment.
Information on chemical uses forms an important part of the ‘exposure scenarios’ to be included in registrants’ Chemical Safety Assessments (CSA). Users who do not submit information and who use substances in a way not covered by the exposure scenarios will have to complete their own CSA once that chemical has been registered. Some organisations may wish to do this if they do not want to divulge information on substance uses due to commercial sensitivities.
ECHA has a fact sheet on how to make chemical uses known to suppliers, click here for further details.
The 30th November is also the final deadline for the late pre-registration for substances that require registration by 30th November 2010 (see above). This deadline applies to companies who are in the first 6 months of importing, manufacturing or using (i.e. in articles, as defined by the Regulation) a phase-in substance. Late registrations need to be submitted through the REACH-IT portal: for further details on how to do this click here.