3rd REACH Deadline

The third and final deadline of REACH (Registration, Evaluation, Authorization and Restriction of Chemicals) falls on May 31. It applies to chemicals produced in, or imported into, the European Union in annual volumes of 1–100 metric tons.

The European Chemicals Agency (ECHA) which manages the technical, scientific and administrative aspects of REACH, expected over 20,000 substances to be registered. For the first deadline, they received dossiers for almost 3,400 substances, and almost 3,000 for the second one. However, only 7,500 substances were registered till mid-March. It is unclear if there is a problem with the estimations or with the registrations.

Under normal circumstances, it would be illegal to continue manufacturing and importing affected substances not registered on the EU market after May 31. Companies breaching REACH could face administrative orders, fines, or even criminal charges levied by EU member state enforcement authorities.

Due to missing data, many registrants might not be able to submit a complete dossier by May 31. Under certain well-regulated conditions, it is possible to submit incomplete dossiers. These must then be corrected within a fixed period. During this period substances may continue to be manufactured and imported. To do so, the registrant must prove that all missing studies have been commissioned by March 31, 2018. Whether this proves itself in practice remains to be seen.