On March 1, 2013, ECHA published a notice, reminding registrants to contact ECHA for solutions to problemsprior to the approaching submission deadline on May 31st 2013.If confronted withextenuating circumstances or situations that delay submission of registration dossiers the ECHA reminds registrants to seek its support immediately.
The first registration deadline in 2010 highlighted a number of special situations that could delay timely submission. According to a report conducted by the Directors Contact group (DCG) of ECHA, European Commission, ECHA and six European industry associations found and confirmed some special situations under which problems did not come from registrants themselves, but were caused by some other factors that lead to untimely submission of complete registration dossier before registration deadline.
As the second REACH registration deadline fast approaches, some registrants are now dealing with the similar problems and may be unable to submit the complete REACH registration dossier in due time. The DCG of ECHA has confirmed this situation and ECHA has made a public announcement to provide help to companies under such special situations.
According to DCG, there are in total four special situations when the timely submission of registration dossier cannot be met:
>> Registrant unable to provide data required in Annex VII and Annex VIII in EU REACH regulation, or importer of mixture unable to obtain substance composition and analysis data from his supplier;
>> Unable to submit pre-registration dossier because of legal entity conversion;
>> LR fails to submit complete REACH registration dossier before due;
>> Downstream user has to assume the obligation from supplier as the imported substance has never been registered by any EU suppliers before.
In ECHA’s website DCG, detailed explanations of these circumstances have been expounded. In addition it emphasizes the compulsory information requirements for submissionand the potential consequences for omission of obligatory information.In the meantime, registrants facing these circumstances seeking more detailed explanations should contact the ECHA or DCG immediately.
ECHA also says registrants who fit these criteria should contact the ECHA and provide a detailed justification for potential delaysandthe compliance steps already in place.. The take home message is to report any problems immediately to the ECHA wait for their evaluation and advice and then act on the advice in a timely fashion.
