REACH Centrum Slovakia s.r.o.
Hattalova 12, 831 03 Bratislava 3
Bratislava, 28.11.2011
Dear Mr., Mrs.
when producing and importing chemical substances in/into the European Union (EU), it is neccessary to learn and keep track of the obligations set out by the EU legislation. The legislative rules apply to all chemical substances, wheter they are being imported as such, or as apart ofchemical mixture orarticle. The regulations, which define these obligations (mainly the Regulation of EP and CouncilNo. 1907/2006 REACH) are fairly complicated, while at the same time, their extent (including the support and guidance documents essential for proper interpretation) is estimated to be well over several thousand pages long.
Herewith we would like to bring to Your attention that the registration period of 1st June 2013for substances produced and/or imported in quantity of 100-1000 ton per year is approaching fast. It is reasonable to assume that the obligations will not only affect large producers of chemicals, but also will bring a considerable burden on small and medium sizedenterprices, which either produce or import chemical substances, mixtures and articles into the EU. The obligations will surely affect companies with non-chemical nature from every field of industry – that is,if they import chemical substances and/or preparations into the EU for use inproduction process, and even if as part of production process there are chemical by-products being produced, which are subsequently placed on the EU market.
The European Commission has serious concerns wheter the aforementioned legal obligations could actually be managed. This is because of the small and medium sized enterprisesbeing affected might not have sufficient technical, expert and language capabilities to fully understand and tackle their legal obligations.
What obligations should You expect to encounter in the upcoming period?
- Registration of chemical substance(s), which are imported into the EU in quantity of 100 – 1000 ton per year, and possibly alate pre-registration, which further relate to:
•Use of approved electronic tools (software) such as UICLID 5 andREACH-IT
•Management of communication within SIEF, and possibly a coordination betweenindividual registrants
•Processing of prescribed test data package
•Preparation and submission of registration dossier
- Notification of particularly dangerous substances being a part of finished articles or chemical mixtures
- Notification of chemical substance classification and labeling to European Chemicals Agency (ECHA)
REACH Centrum Slovakiais alegal entity established by the Association of the chemical and pharmaceutical industry of the Slovak Republic with the aim of providingsupportive, consultancy and advisory services.
REACH Centrum Slovakia offers You ahelping hand in managing the obligationsin accordance with the EU chemical legislation(RECAH, CLP).
REACH Centrum Slovakia offers You ahelp of experienced specialists with establishing user account at the REACH-IT portal;with chemical substance pre-registration; with data processing required for preparation of registration dossier;with processing and input of data into the IUCLID 5 database; with completion of the required forms and notification documents for substance(s) You placeon the EU market.
The deadlines set out for completion of the briefly described legislative requirements are relentlessly approaching. We would like to help You to be timely and well prepared in order to fulfil Your obligations and to avoidpossible mismanagementresulting in halt of Your imports into the European Union.
For further assistance please contact us .
We look forward to future cooperation with You.
With regards,
Ing. Štefan PetkaničRNDr. Zuzana Zajacová
Managing Director Executive Director