there is no pre-registration facility, registration must be submitted: tonnes per year. you cannot late pre-register and
and no extended registration • Within six months of first However, if that first import you cannot take advantage of the
period, available to you. breaking through the annual was, say, on 1 February 2009, extended registration deadlines.
1 tonne threshold; AND your late pre-registration must If you do find yourself in this
When to late pre-register • At least 12 months before the be submitted by 31 July 2009 situation it’s not necessarily the
The good news is that for eligible registration deadline relevant – 6 months after breaching the end of your business in that
substances you don’t need to to the substance and tonnage 1 tonne threshold. substance, but you need to
submit a late pre-registration band. register the substance before
before you first break the 1 tonne For example, if you first imported Missed the pre-registration you can continue manufacturing
barrier: no crystal ball gazing 1200 tonnes of a substance window in 2008? or importing it. Our bespoke
or forecasting is required! sometime after 1 December If your company imported or REACH Reassurance
However, late pre-registration 2008, the window for late pre- manufactured 1 tonne of more consultancy programme can
doesn’t last forever and there registration may be open to per year of a phase-in substance help you move towards securing
are some constraints on when you until 30 November 2009 – between 1 June 2007 and compliance – contact the
the information can and must 12 months before the registration 1 December 2008, but missed Helpdesk for more information on
be given to ECHA. A late pre- deadline for substances >1000 the initial pre-registration window, 020 7901 1440.
SIEF formation and the SIEF Formation Facilitator
In the last REACHReady for management services at A commonly accepted model, early days may decide to take a
Review we shared our commercial rates. promoted by CEFIC, defines four more active role if they find that
thoughts on life in the pre- If you disagree with the categories: the substance later becomes
SIEF, the entity comprising all appointment of an organisation 1 Leader more commercially important to
pre-registrants of a substance. offering to lead the SIEF and 2 Active them.
Since pre-registration closed manage its affairs, even if they 3 Passive (inactive “follower”)
last year, the REACHReady ticked the box to volunteer 4 Dormant SIEF formation and its
helpdesk has received many when they pre-registered, you These categories were defined costs
enquiries about the next step: can object: SIEFs should be by industry to help its members: A SIEF should not cost anything
SIEF formation. In this issue formed on consensus through a they are not official regulatory to join: every potential registrant
we are going to give you an democratic process. positions; they have no legal has the right to be a member.
insight into the role of the SIEF basis and are not binding. If a However, the manager of a SIEF
Formation Facilitator (SFF) in Categorising the status of company wishes to be active in and/or lead registrant can ask
establishing the SIEF. pre-registrants a SIEF initially but later decides members of a SIEF to contribute
Many facilitators have devised they are happy to be less active, to running costs where there has
SIEF Formation Facilitator strategies to divide the pre-SIEF they can adopt a more passive been mutual benefit, provided it
Any pre-registrant can volunteer members into different groups stance. Likewise, a company not is shared on a fair and equitable
to be the SIEF Formation to ease the burden of SIEF taking an active role, perhaps basis. Of course, what is “fair”
Facilitator: it doesn’t have formation and administration. even in a dormant position, in the is open to discussion but if you
to be the highest-tonnage
manufacturer or importer, the
eventual lead registrant, or even A few tips
the largest company. The role of
The REACHReady team have come up with a ✓ Remember that online and commercial SIEF
the facilitator has no legal basis
few points to help you on your way as your software tools are available to help you. They
under REACH, and the position
SIEF is established: may save you and your SIEF time and money,
of any organisation claiming the
but they are voluntary.
right to be one is not definitive. ✓ Decide whether you are happy with the
✓ You are free to change your status in the SIEF
Those offering to be facilitator did volunteer facilitator.
at any time: remember that if agreeing to share
just that – they simply took the ✓ Cooperate with the facilitator; they took the
costs you may still be liable under commercial
initiative to help SIEF formation. initiative for no financial reward.
agreements even if you later decide against
The motives of volunteer ✓ Clearly communicate your registration intentions
registration.
facilitators will differ: some and your envisaged role in the SIEF. Do this in a
companies have a lot of reasonable time frame.
commercial interest in driving ✓ If the SIEF appears to have good leadership
the registration forwards, and you are happy with the facilitator, do not
some members of existing hinder progress unnecessarily.
industry sector groups will ✓ Remember that you may be able to join a
have consortium management consortium: if membership is offered,
expertise and experience to offer. consider potential benefits as well as costs.
There will also be consultancy ✓ If asked to agree in advance to pay an invoice,
firms offering good management acknowledge that you will pay YOUR fair
skills and will already have share of costs and for data YOU need before
in place mechanisms for registration.
recording time and charging
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