The Directors' Contact Group (DCG) - a platform of the European Commission, ECHA and industry associations – has identified exceptional scenarios where registrants may, through no fault of their own, find it difficult to submit a complete registration dossier by the registration deadline.
ECHA is again offering help for companies affected by the four scenarios identified by the DCG. ECHA does so either by relying on its discretionary rights under REACH or by providing companies with a transparent means to demonstrate good faith.
The four scenarios where exceptional circumstances could apply are:
- Completeness of dossiers - Companies that may have difficulties in providing data required in annexes VII and VIII of REACH in due time or importers of mixtures that have difficulties in getting compositional and analytical data of the substances in the mixture from their suppliers (Issue No. 10)
- Legal entity change - Companies that do not hold a pre-registration due to legal entity changes (Issue No. 15).
- Dependency on the lead registrant - If the lead registrant fails to submit a complete registration dossier on time, the member registrants may need exceptional support (Issue No. 20).
- Substance with no registration intentions - If no registration is planned for their critical substances, downstream users may consider taking up the role of an importer and submitting a registration, or engaging another importer to do so on their behalf (Issue No. 21).
The conditions under which the solutions apply are described on the DCG section of ECHA's website. It also describes how an affected registrant should contact ECHA.
Every affected company will need to contact ECHA as far ahead of the deadline as possible, and by 24 May 2018 at the latest. The registrant needs to provide detailed justification of its situation and an explanation of the measures that it has taken to comply with its obligations under REACH. When ECHA receives this information, it will give instructions on how to submit a registration by the deadline.
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