ECHA URGES COMPANIES TO FOLLOW GUIDANCE AND INSTRUCTIONS IN THEIR DATA SUBMISSION

https://www.chemnet.com   Jun 18,2008

Company sign up and pre-registrations

By 13 June 2008, 1427 companies had signed up in REACH-IT and created 7360 pre-registrations.

More than 98% of the received pre-registrations rely on EINECS or CAS identifiers. For the remaining substances which were pre-registered by chemical names or other names, ECHA strongly recommends the use of internationally recognised nomenclature such as IUPAC names. In addition,
the use of English names is encouraged. Consistent use of the guidance for identification and naming of substances is needed to ensure that potential registrants can be grouped in the same pre-SIEF.

ECHA recognises that some companies may have difficulties to find the correct substance name in EINECS and therefore pre-register their substances correctly. Where possible, ECHA will contact these pre-registrants and give them the possibility to re-submit the information in a correct manner.

Submissions via the temporary submission procedures

By 13 June 2008, ECHA has also received 143 PPORD notifications, 38 inquiries, 5 regular registrations and 15 registrations for intermediates. Many of these dossiers could not be processed further because of incorrect information (e.g. missing submission form or inconsistent dossier identification). In addition to industry dossiers, ECHA has also received from Member States 14 proposals for identification of Substances of Very High Concern and 6 proposals for harmonised Classification and Labelling.

For PPORD notifications and registrations which could be processed but which failed the completeness check due to missing or incomplete information, ECHA has granted a sufficiently long time frame for companies to complete their PPORD notifications or registrations. The Agency urges companies to respect the given deadline to have legal certainty of the continuation of their operations.

The first submission of inquiries suggests that in many cases companies have not submitted sufficient
information on substance identification in order for ECHA to be able to carry out its work without
requesting further information to these companies.

ECHA has also noted that a substantive proportion of the submitted registrations for intermediates
have not been preceded by a proper inquiry or pre-registration, indicating insufficient fulfilment of data
sharing obligations.

ECHA will shortly update its temporary submission procedures in order to assist industry in submitting
correct dossiers. It will in particular address errors and data gaps in the information necessary to
process the dossiers and in substance identity.

Technical completeness check

Most commonly occurring errors in the technical dossiers were related to missing information on the
chemical identity and the composition of the substance. In 50% of the incomplete dossiers, either the
correct name or molecular and structural information was incompletely provided. Other frequently
occurring data gaps (30% of “failing” dossiers) were related to incomplete analytical information and
missing contact details of the recipients.

Specific new guidance on completeness of registrations will be published by the end of this month.

Technical improvement of REACH IT

Technical improvement of REACH IT continues. A maintenance release aimed at fixing a number of
known issues was successfully introduced on 17 June. The release notes have been updated
accordingly. This will improve the application for industry users and other users.

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