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have witnessed, on occasion, substances becoming orphaned – that is, the relevant manufacturer or importer has opted not to register the substance, the result of which has meant they cannot be used on the EU market. The first response has always been to find alternative suppliers. But if none have been available, industry has, with the Commission’s backing, circumvented these problems by falling back to a lower tonnage and qualifying for a further delayed registration date. Legally this is perfectly acceptable.


The problem downstream users face in 2018 is that if no other suppliers are available there are no legal options available to companies in the event that a substance on which they depend becomes orphaned. The substances must be registered in full and until that date cannot be used. Some have remarked that they find it surprising that a company may be caught unawares: surely they will know what substances will be registered or not.


However, there are some legitimate reasons why a company will not know: along with the sheer complexity of modern supply chains and the risk that suppliers are simply not aware of the 2018 deadline, some suppliers may simply not disclose that they are not intending to register to run down existing stocks and maintain sales for as long as possible. It means we simply are not in a position to say which substances are at risk or not. The risk is particularly great in 2018 because the cost of registering a substance may be more than its market value as we are dealing with substances used in relatively low tonnages.


Post 2018, if companies find themselves in this position, it could mean manufacturing grinding to a halt as alternative manufacturers are evaluated and possible substitutions are


evaluated. Companies may be forced to import articles from outside of the EU, abandon orders or in a worst case scenario withdraw from a market completely.


Industry has been working hard with its supply chain in an attempt to avoid this situation. But experience has shown that in complex supply chains the risk is significant, particularly at a time when supply chains are under immense pressure because of the uncertainties of REACH registrations due to Brexit.


One option could be a moratorium on enforcement for companies whose suppliers did not register substances by the deadline but can show active plans to find alternative registrants or register the substance themselves or an extension of the registration deadline for companies who need more time to complete testing and/or dossier compilation.


Whatever the situation that the United Kingdom finds itself after it leaves the European Union, industry will need to ensure it retains compliance with European chemical regulations if we are to retain unfettered access to the single market for our products.


LINK susanne.baker@techuk.org


Delivering Excellence Through Expertise.


Technical expertise.


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The complete solution for success www.sealandchem.co.uk | +44 (0) 1606 830145


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