|
|
Global Product Stewardship
The REACH Regulation entered into force on June 1, 2007. The pre-registration period will last 6 months, from June 1, 2008 until December 1, 2008. Pre-registration of the so-called phase-in substances will be extremely important because manufacturers and importers that pre-register a phase-in substance will be able to continue manufacturing or importing it without interruption. However, companies that do not pre-register that substance as if it were truly "new" may experience an interruption in their business activities. At least 30.000 phase-in substances fall within the scope of REACH. Industry will have an opportunity to register these substances during the 11-year window following REACH's entry into force according to a phase-in schedule, but only if the substances were pre-registered before the anticipated December 2008 deadline.
Therefore, the time for companies to select the phase-in substances that they will pre-register in Europe is now. It will take time to create or update their chemical substance inventory, to evaluate supply chains and identify exactly where the vulnerabilities are, to calculate the business impact of those vulnerabilities, and to develop and prioritize the projects that will proactively address these issues. 2007 and 2008 will be important and strategic years for companies that are managing the implementation of REACH and GHS. A sharp increase in activity prior to and during the pre-registration period is to be expected. In addition, companies that are inadequately prepared should expect significant ramifications.
The ARCADIS Global Product Stewardship team helps clients to develop and implement a REACH management framework that is organization specific, and assists them in the fulfillment of their obligations as producers, importers, distributors and/or downstream users of substances, preparations and articles under REACH.