2018 REACH Registration

In the wave of the final phase of REACH Registration, the European Chemicals’ Agency, ECHA have released some interesting statistics.


REACH registration duties apply to EU manufacturers and EU based importers of substances from outside the European Union (EU), produced or imported in quantities exceeding 1 tonne or more per annum (1 t/a). Substances that are intentionally released from articles are also subject to registration.


Product mixtures do not need to be registered, but importers must collate the volume of constituent substances and register those substances that exceed 1 t/a .This could be expensive if several constituent substances exceed the threshold.


Suppliers from outside the EU are not permitted to register directly, but may appoint an ‘Only Representative’ in Europe to act on their behalf. For non EU suppliers, this option prevents any potential issues with disclosure of intellectual property and protects supply to the EU market. This also frees their EU importing customers, who are then considered downstream users without registration duties.


REACH Registration has been managed in a phased approach and the final deadline is approaching for lower volume substances, produced or imported between 1 and 100 tonnes per year, which must be registered by 31 May 2018.


As of the 17th April, ECHA report:


  • 20,481 registrations so far submitted
  • 8,230 unique chemical substances
  • Most registrations filed from Germany, the UK and France


Note: the number of registrations exceed the number of unique substances registered because organisations must enter into joint registration for the same substance for data sharing purposes, to avoid unnecessary animal testing.


The majority of registrations were made by Importers and Only Representatives of non-EU organisations:

  

Role in supply chain            Registrations         %           Substances
Importer                                     8816                             43           3749
Only Representative            5831                              28            2774
Manufacturer                        4774                             23           3404
Manufacturer & importer    1059                           5               914


The number of substances registered by Only Representatives and importers amount to a whopping 14,647 registrations (71%), 6523 individual substances. It suggests that almost double the number of substances in the tier 1-100 tonnes are being supplied from outside of Europe, than manufactured within the EU, or at least that EU manufacturers are willing to register.


It is encouraging that importers are aware of their REACH registration duties, as this was questioned along the REACH Road. It would be interesting to know whether importers are registering substances for supply to the market place, or to ensure the continued supply of substances in their mixtures, and therefore supply of their mixtures to market.


Geographically, the most registrations were filed from Germany, the United Kingdom and France, followed by Italy, the Netherlands, Belgium and Spain respectively:

  

Country                  Registrations       Substances 

Germany                   5495                         3452
United Kingdom  2612                          1450
France                       2087                        1370


The number of UK registrations is surprising, considering uncertainty regarding the status of UK REACH registrations, post-BREXIT. ECHA’s Interactive Infographic shows that almost 50% of the above UK registrations were filed since May 2017.

 

ECHA’s Infographic provides an interesting statistical perspective on the registrations received from the 28 Member States and from the European Economic Area countries, Norway, Iceland and Liechtenstein.


ECHA Report the following information can be obtained:

  • No. unique substances registered, registration type (full or intermediate), substance type (existing or new) and approximate total tonnage on the EU/EEA market;
  • No. registrations, type (full or intermediate) and role of the company that submitted the registration (manufacturer, importer, etc.);
  • most commonly registered chemicals;
  • the information above, filtered by individual EU/EEA country and by year, month or week;
  • No. unique companies that have registered, company size and role in the supply chain https://echa.europa.eu/regulations/reach/registration/registration-statistics

The number of registrations is significant, but far short of ECHA's estimate of up to 

60 000 registrations, representing up to 25 000 substances, three times more than for either of the previous deadlines. Time is now limited, but a final wave of registrations may be submitted before the deadline. The final figures will eventually be released by ECHA and will make interesting reading.



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Page updated 12 July 2018