“Approximately 2.7 million pre-regis-
trations have been filed—roughly 13
times higher than originally
estimated by ECHA”

dossiers for them with ECHA.

Also by the same date, all chemicals over a one-ton output, which are classified as being category one or two CMRs—carcinogenic, mutagenic or toxic to reproduction—must be registered. In addition substances above 100-ton annual production, which are classed as persistent, bioaccumulative and toxic (PBT) or very persistent and very bioaccumulative (vPvB), will have to be registered.

ECHA estimates that approximately 9,000 chemicals will need to be registered by the end of November, equivalent to between a third and a quarter of the total to be registered under REACH. But they are the ones requiring the most work in terms of gathering of safety data because the higher the volume the more test data is required by the legislation, while even more information is demanded for the safety profiles of CMRs, PBTs and vPvBs.

“There is now a real possibility that because so much needs to be done between now and the end of November that a lot of companies will not be able to meet the deadline and will have to take their products off the market,” said Jo Lloyd, technical director of ReachReady, a consultancy set up by the UK Chemical Industries Association (CIA) to provide guidance on the legislation.

The major problem is that large numbers of SIEFS are not working properly. Communication between the members, which can range from a few companies to several thousand, is poor. There are also arguments within SIEFs about how much individual members should pay for test data, particularly when it is provided by another SIEF member.

Companies within SIEFs have been slow to agree on which one of them should be the lead registrant. This position has the responsibility of drawing up the basic registration dossier to which the individual members will add their own specific data, such as information on the use and application of the chemicals among their customers.

ECHA was estimating at the beginning of the year that approximately 2,000 SIEFs for substances due for regis-

EUROPE

International Coatings Scene tration in 11 months had lead registrants, leaving 7,000 without someone organizing the creation of the basic dossier. Earlier the agency had warned that the basic dossiers should be completed by midsummer to leave individual companies time to add information for their individual registrations.