2010 30 November the EU REACH regulation first must complete the official registration deadline for the registration of substances. Then, if the related enterprises by the European Chemicals Bureau (ECHA) the requirements for registration, the merchandise involved relevant substances will be EU 27 countries.
Since June 2007 REACH regulations and policies into effect has been officially announced, over 3 years, 3 years long REACH registration "Marathon", the Chinese enterprises have been challenged, there have been expectations, have had to struggle ...
Now the time has arrived in September 2010, from the date of the deadline is less than three months. Seeing this "Marathon" in the first part of the tournament is about to usher in a Sprint, Sprint is proclaimed the State players now?
Official registration number substantially shrunk
Department of Commerce REACH consulting service center related staff told reporters that at present, the official registration of enterprises with more than 50, only reach pre-registration number of 10 per cent, participated in the preliminary registration of 2000 more substances, now only 50 kinds are officially registered. These figures do not ban people's consent.
Back in June 2008, the European Chemicals Bureau (ECHA), started to REACH regulations phased substances pre-registration, for a transitional period, many domestic companies are scrambling to provide its goods involving chemicals for pre registration, hot scenes. In 6 months of the registration period, domestic enterprises to participate in pre registered about 65000 involving substances 146000 multiple times, the preliminary registration of 2750000 times, each entry digital have greatly exceeded the projected before ECHA.
When the Fiery pre-registration is it really just come to a dismal?
According to the Department of Commerce REACH consulting service center, decided to 2010 year officially registered companies are actively making file the required information. At the time of registration of the enterprise are largely based on exports of the enterprise itself actively applying for adjustment of the registered tonnage, the extension of the transitional period. Many pre registration phase blindly enterprises after a period of consideration that the REACH regulatory registration instead of the actual operation of the enterprise, and give written notice to the Service Center immediately REACH regulatory registration.
The industry insiders told reporters, many enterprises because of the cost of scruples and take a wait-and-see attitude, waiting for the final testing costs to determine the matter before the trade-offs. Due to the participation of the same substance detection of all enterprises will cost sharing experiments, a substance is concerned, to participate in testing of enterprise, the more their assessed costs lower. However, enterprises are watching, participating in "AA-" the fewer number of enterprises, the cost of each enterprise. As a result, the enterprise will be formally registered more prohibitive, resulting in a vicious circle.
Should REACH difficult lot
Under REACH regulations, registered users will need to pass through the same physical potential registrant of substance information exchange forum (SIEF) Exchange and sharing of data. China and the substance of the registrant, some of the potential participants of the SIEF and even more than 5000, this resulted in a SIEF internal exchanges and discussions very difficult, almost impossible to run efficiently.
As of 2010-30 August, the global total of 2697 a SIEF potential registrant to apply to become a leading registered ECHA, and through pre-registration total 146000 SIEF formation. In other words, the worldwide only less than 2% of the SIEF more active.
In addition, according to the REACH regulation, required by the lead registrant submits the registration file in the joint submission section. The lead registrant should be elected by the industry, but in the current environment of SIEF confusion, it is virtually impossible to achieve. Furthermore, ECHA does not provide a relevant regulations to limit lead registrant relinquish its obligations, it also makes the participants increased uncertainty.
The registration obligation, under the REACH regulation, all in EU production or export to the EU total more than 1000 tons/year of substances must be at the 1 December 2010, recently completed full registration. In addition to collect within the SIEF existing data, and analysis of data gaps, and contact compliant laboratory on the missing data for test or to submit a proposal, ECHA and preparing for trial registration dossiers and submit. Obviously, most of the work has not been completed, the company completed its first registration in difficulty will be very large.
Remove such relatively objective, subjective factors from the enterprise is led to the formal registration key to dramatically shrink. However, regardless of whether you decide to participate in a formal registration that involve exports to the EU's enterprise needs to REACH regulatory policies pay enough attention to and understanding of, on balance, based on the long-term interests of enterprises and the development of a positive response. 1234
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