First REACH Registration Deadline Approaches

In effect for more than two years, the Registration, Evaluation, Authorisation and Restriction of Chemicals (REACH Regulation) presents its first registration deadline in less than one year. While many companies will only have to register their pre-registered substances by later deadlines, the joint submission is likely to have to be submitted by November 30, 2010. The mandatory joint submission of certain information to the European Chemicals Agency (ECHA) requires cooperation and data sharing between registrants, but also must be in compliance with European Union (EU) competition law. Member states are responsible for enforcing REACH obligations and have already taken enforcement actions, with many more expected to follow. In preparing the joint submission, companies must comply with regulation guidelines and EU competition laws and understand the potential penalties and enforcement actions by member states.