Ten years of REACH

The industry is gearing up for the end of the last and final transition phase: until May 31, 2018 substances in amounts between 1 and 100 tons have to be registered. The deadline next the registration has to be completed until 31, 2018 but the deadline is closer than that. The prerequisite for a registration is that a substance is pre-registered first – the deadline for pre-registration is May 31, 2017.

Implementation issues

Not only the impeding deadline but also the numbers show that REACH has definitely grown out of infancy: in the last ten years ca. 50.000 registrations dossiers have been handed in to the ECHA, who estimates about the same number to be added until the end of the last deadline.

However, a fair share of companies is still struggling with the implementation of REACH – especially SMES are affected. This also became present in a study by the Environment Federal Agency (UBA) in 2015. The numbers from two years ago show that more than half of the REACH registration dossiers do not comply with one of the seven data request which are examined, 27 % even fail to fulfill two or more.

What is your verdict on REACH after ten years? Are you seeing improvements or is the implementation of the legislation still a problem?