- Being part of the European development
- The list of pre-registered substances published
- Matti Vainio: "Socio-economic analysis is not an afterthought"
- Ulrike Kowalski, Chair of the Forum: "REACH enforcement has started"
- The Risk Communication Network (RCN) invites stakeholders as observers
- Appointments to the Board of Appeal
- Visit of the Delegation of the Court of First Instance to ECHA
- Quality - a catalyst for excellent performance
- ECHA inaugurated its new conference centre
- Interview: Jef Maes, Director of Resources
- Out and about
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Article related to: News from ECHA
The list of pre-registered substances published
ECHA published an updated list of preregistered substances on 27 March 2009. This is the last major update of the list that ECHA expects to make. This note outlines how ECHA arrived at the update; how to search the list; what to do if a substance you manufacture or import is not on the list; and how to use the list to move between (pre-) SIEFs in REACH-IT.
The Agency published a fi rst interim list of pre-registered substances in October and an update in November 2008. However, a complete list could not be prepared until the deadline for submission of pre-registrations on 1 December 2008. Following the deadline, the Agency had 146,014 substances, pre-registered by over 65,000 companies. The Agency also had a deadline, imposed by the REACH Regulation, to produce a list before 1 January 2009. That meant that a list had to be produced before Christmas.
Checks to increase usability
The REACH Regulation invited companies to pre-register substances that they may register later.
The substances that were pre-registered included the whole of the EINECS list (European Inventory of Existing Chemical Substances). The first list of pre-registered substances also included a number of articles and preparations which were not supposed to be pre-registered at all - articles, which are exempt; and preparations, which should not be pre-registered but whose constituent substances should have been. It is important to note that the pre-registrations, and consequently the list, comprises submissions made by industry. It is not an "ECHA list".
However, ECHA has tried to make the list as useful as possible by checking, as far as we were able, the submissions made. Up to the last two weeks in November, ECHA had managed to check some 12,000 substances and had sent out around 9,000 e-mails to companies seeking confi rmation of substance identity. We received around 300 replies.
Identifying numbers and doubles
After the end of November we divided the pre-registrations into groups: substances with EC numbers; substances with CAS numbers; and substances without CAS numbers but with seemingly plausible chemical names and reaction masses which often comprised lists of substances which were already listed individually.
The Agency has managed to remove the obviously spurious pre-registrations and to have the substances which had been preregistered with CAS numbers checked by CAS. Also some of the repeated pre-registrations were reconciled. The new March 27 list includes the substances with newly identifi ed CAS numbers and at the same time the reconciliations and deletions reduced the list further to 143,000 substances.
Some doubts remain
However, the list does still contain a large number of pre-registrations without CAS numbers or names. This may be because of mis-spellings, or mis-naming or because the substances have never been registered with CAS. In addition, there is still a long list of "substances" identifi ed as reaction masses but which are likely to be mixtures, preparations or simply individual substances pre-registered in the wrong way.
The list is now available on ECHA website. It includes improved search functions and is available in several formats to download.
Value for SIEFs
The Agency recognises that the list is of limited use for narrowing down the intention to register, as several companies preregistered their complete EC inventory. We also recognise that some of the registration deadlines entered (these are determined by tonnage bands submitted by companies) are likely to be mistakes. Consequently, as with EINECS, the list as such is not a clear measure of intent to register. At the same time, the Agency recognises the value of the list in the next step of the REACH process, in helping the formation of SIEFs (Substance Information Exchange Fora). Essentially, companies that have pre-registered the same substance have to determine whether they do in fact have the same substance. Where they do agree that they have the same substance, they form a SIEF.
How to find the right pre-SIEF
Consequently, as SIEFs form we would expect some of the original groups, the "pre- SIEFs" to split and merge; individual companies may also leave the groups as they realise that they do not manufacture or import the same substance as everyone else.
One way of working out where to move is to search for the appropriate substance in the list, and then go back in to REACH-IT. Enter that substance name in the "similar to" tab of the pre-registration and then view the correct "pre-SIEF". The members may then be contacted outside REACH-IT. Companies that made mistakes in preregistration (mis-spelling a substance or choosing the wrong substance) or those seeking to access data on similar substances may use the same process.
Information for downstream users
Downstream users may also access the list to determine whether the (phase-in) substances that they use have been preregistered. If they have not, they may then notify their interest in the substance to the Agency. The Agency will, in turn, publish the name of the substance on its website and on request provide contact details of the downstream user to a potential registrant. In conclusion, the list is a compilation of pre-registrations made by industry. The entries have been checked, as far as that has been possible in a short time. The list is not a good measure of "intent to register" by a particular deadline but will help companies seek out the right SIEF, or the right data.
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Biocidal Products Committee:
26 February-1 March
Committee for Risk Assessment:
6-8 March and
Committee for Socio-Economic
Management Board meeting:
23-27 March (tentative)
Member State Committee:
20-24 April (tentative)