UK Current Survey and Legal Update

摘要

Chemical substances - the process of pre-registration has commenced - a new fee structure is in place - to be administered by European Chemicals Agency - the UK is consulting on new enforcement provisionsrnThe EC REACH Regulation for the Registration, Evaluation, Authorisation and restriction of CHemical substances' entered into legislative force on 1 June 2007 throughout Member States. It has direct effect without the need for national transposition. It establishes a regime for the regulation and safe use of chemicals for those companies who deal in quantities of chemicals greater than one tonne per year, requiring the pre-registration of qualifying chemical substances.rnThe process of pre-registration has now begun for those companies who deal in 'phase-in' substances, namely substances which are listed on the EINECS2 and already known in the EU. Essentially, the process of pre-registration is designed to give the producer a 'breathing space' before formal registration - a complex process -enabling the substance to be used in the interim. Pre-registration, however, must take place between 1 June and 1 December 2008 in order for companies to benefit from the staggered approach. A failure to pre-register a phase-in chemical substance with the European Chemicals Agency3 prior to the deadline could lead to a manufacture/ importer being banned from trading in that substance until a full REACH dossier has been submitted, leading to cost and resource implications. Inevitably, a failure to pre-register may also have implications for forward sales of 'registerable' substances.