Industrial companies located in countries outside the European Union face a new challenge caused by the EU regulation of chemicals, REACH. Non-EU manufacturers and formulators of chemical substances, preparations and articles have two options, if they want to continue export to the EU: either to appoint an Only Representative located in the EU who can comply with the obligations of importers, or to leave the EU customers with the burden of REACH registration and support them with data. The latter option is often not attractive seen from the customer’s perspective.
Appointment of Only Representative
DHI has entered an agreement with a large company in Japan, which has appointed DHI as the company’s Only Representative with regards to the obligations of an importer under REACH.
The collaboration was initiated by negotiations on the Only Representative agreement and the content of the associated technical consultancy.
With the mutual agreement completed and signed, the next step was to submit pre-registrations for the substances covered by the agreement before the deadline by December 1, 2008.
By submitting a pre-registration, the company can buy at least two years relieve before the next sharp REACH deadline soonest in 2010.
Consortia and SIEF
Although the earliest registration deadline is November 30, 2010 (when pre-registration has been submitted), industry has already initiated collaboration for the purpose of registration.
DHI represents the company in a consortium which includes several potential registrants of the same substance. The tasks of the consortium include identification of the need for further information on the hazards of the substance, which may be obtained by additional experimental studies.
The consortium members will enter a Substance Information Exchange Forum (SIEF), together with other registrants, and continue the evaluation of data according to the requirements for the chemical safety assessment and the registration.
As Only Representative, DHI is responsible for providing all the documentation required for the registration in close collaboration with the company.