The EU REACH Directive: A New Interpretation by the Sole Representative
On April 14, 2008, the European Chemicals Agency (ECHA) held a REACH Workshop in Brussels, Belgium – the final stage of pre-registration and registration of chemicals. Otto Linher of ECHA explained that the sole representatives (ORs) appointed by non-EU manufacturers for chemical registration will now be able to submit separate registrations for each manufacturer. This change was a conclusion reached during further exchanges of views among member states. Under the previous interpretation of the directive, if an OR was the sole representative for the same substance from multiple non-EU manufacturers, the quantities of the same substance from all represented non-EU manufacturers should be combined and submitted together in a single registration. This practice will now be abolished. ECHA also guaranteed that the REACH-IT system, along with pre-registration, would be completed by June 1st. ECHA also announced that two incomplete guidance documents would be published in May, covering Chemical Safety Reports (CSRs) and Substances in Articles. REACH Registration and Pre-registration: REACH registration and pre-registration will begin on June 1, 2008, and will last for six months, ending on December 1, 2008.