The information gap

摘要

Chemical substance producers did well to complete their registrations by the first deadline in 2010, as argued in this month’s Guest Column (see page 24), but the fact remains that many dossiers were not up to scratch. More than two years after the registration deadline, ECHA’s first substantive actions against noncompliant dossier are only just coming to light. This is partly because it has taken time for the agency to sift through the dossiers, and because the follow-up procedure for requiring registrants to improve their dossiers takes time. But it is also because the REACH Regulation is silent on what should happen if a registrant fails to supply the additional information requested. As a result, ECHA and the member states have had to devise their own system for connecting the agency’s activities to ensure compliance with that of national authorities. But the new links in the enforcement chain, the “statements of non-compliance”, or Soncs, are not being published by ECHA on the grounds that doing so could jeopardise any future investigations by the national authorities.