REACH pre-registration: participation has the right to speak

The pre-registration of REACH (Registration, Evaluation and Licensing of Chemicals) from June 1 to November 31 this year is already “on the fly”. Those who fail to pre-register within the time limit will be suspended from EU-related business. . Representatives of the REACH related work of the China Petroleum and Chemical Industry Association and representatives of several REACH registered service agencies pointed out in an interview with reporters that once the pre-registration is missed, products will not be directly exported to the EU; direct registration will require large amounts of data to be purchased, registration costs Will greatly improve. Only by conducting REACH pre-registration, can we have the right to speak and gain the initiative to trade in the EU.
The pre-registration period is within easy reach. The EU recently issued a 140-page REACH data-sharing guidelines document, which provides an explanation of the information sharing mechanism of “existing” chemical substances.
According to Yang Weicai, vice president of the China Petroleum and Chemical Industry Association, the annual production or import of chemical substances equal to or more than 1 ton shall be pre-registered with the European Chemicals Agency. The pre-registration period is from June 1, 2008 to November 31, 2008. Non-EU producers (such as Chinese manufacturers) may register for imported products through their EU importers or entrusted “sole representative”.
Relevant units have been pre-registered through the European Chemicals Agency's "REACHIT" system to extend the registration period. He said that pre-registration is very important for more than 90% of chemical companies, especially for key products such as inorganic salts, dyes, pigments, rubber products, organic intermediates, and exporters of bulk products. Only companies that participate in pre-registration can become members of the “Materials Information Exchange Forum”, share registration data in a fair and open manner and at a reasonable cost, and negotiate classification and labeling methods for related substances to win the right to speak. Otherwise, after the pre-registration period is over, the European market will be closed to the company.
Pre-registration is more effective. According to Prince Min, deputy director of the information and marketing department of the Petroleum and Chemical Industry Association, pre-registration requires only simple information such as identity and material name provided by the registrant. Companies only need to fill in simple information and provide relatively few data, so they can share the registration information with other companies participating in the pre-registration at the time of formal registration, and can also put forward their own suggestions and opinions. Chemical manufacturers, downstream users, and traders will be involved in any form of export to Europe. The pre-registration of REACH is definitely a time-consuming and arduous task for companies.
Chen Qixun, head of Beijing Yingshida Information Technology Co., Ltd., who participated in the REACH research organized by the Ministry of Commerce, told reporters that the pre-registration fee is very low. Companies that have completed pre-registration also enjoy the right to continue exporting products to the EU while completing formal registration procedures. Enterprises participating in pre-registration can obtain a large amount of information through the “Materials Information Exchange Forum” and have the opportunity to express their opinions and strive directly for their own rights; they can provide enterprises with no pre-registration with compensation for the use of export rights, and not only can recover certain costs. It can also impose certain restrictions on competitors.
Director of the Department of Production and Operations Management of Sinopec said that REACH involved more than 90% of exports to the EU. According to the provisions of REACH, regardless of who is registered, we must provide complete information on the industry chain. Everyone must grab time, collect more data, and allow as many companies to pre-register. Once the EU door is closed down for business, it is necessary to renegotiate. The data required for direct registration will be huge, the workload will increase exponentially, and the cost will be high. Therefore, anyone who goes through pre-registration and registration will have the "right to death" of exporting to the EU.
Mastering common skills to deal with the door Pan Derun, vice president of the Petroleum and Chemical Industry Association, hopes that multiple manufacturing companies of the same product can jointly register to share resources and reduce registration costs in a joint registration model. According to Prince Min, when enrolling joint elbows, registrants need to jointly submit information such as toxicity, classification, and labeling of chemicals. Other information required for registration, such as guidelines for the safe use of chemical substances and chemical safety reports, may be submitted jointly or separately. Business sensitive information, patent protection content, etc., can be submitted separately, and consultations with the EU are required to submit such information.
The European Union stipulates that submitting information that does not meet the requirements of REACH will also be considered fraud. Enterprises need to categorize statistics on the chemical substances involved in export products, prepare relevant registration documents, and communicate with relevant raw material suppliers to negotiate solutions so that pre-registration can be conducted smoothly and unnecessary troubles can be avoided. It is understood that foreign and Sinopec subsidiary companies of similar size, responsible for the REACH work of about 20 people, in addition to hundreds of people part-time work. And the bigger the company, the more products, the longer the preparation time required. Therefore, experts advise that companies should seize the time and prepare for REACH pre-registration.
In addition, the EU's detailed rules on pre-registration are still being added. It is not known whether many REACH registered institutions and intermediary agencies meet the requirements of the EU. If companies choose to carelessly, they may cause various disputes and even lose the European market. . To this end, experts have warned that companies must be cautious when they choose to register as the sole agent. Do not behave rashly because of the pre-registration time.

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