In light of the upcoming registration deadline on May 31, 2018, companies that fail to register their substances under REACH are left with few options. In accordance with the principle “no data, no market” (Art. 5 REACH Regulation), it is recommended to register substances on time, when possible. Pre-registrations with compliant dossiers will become invalid and SIEFs inactive after the submission deadline (May 31st). Registrations submitted after June 1st will undergo more complex inquiry procedures.
It is important to note that selling stocks of unregistered substances produced in, or imported into the EU/EEA before the deadline can be risky, because downstream users may not be willing to use them.
However, ECHA provides assistance to registrants facing exceptional situations defined as follows:
- Lack of necessary data (on substances in mixtures, unavailability of data required in annexes VII and VIII),
- legal entity changes,
- failure of the lead registrant to complete his obligations before the deadline,
- SIEF without an EU manufacturer
