I presume you're all organised and perhaps even a bit optimistic about this REACh thing. But don't get too laid back, whatever you do. Remember what the Good Lord said. "Smile and be happy, for it could get worse". So I smiled and I was glad ..and it did. The powers-that-would-be have made a very strong statement : No data, no market. If so, next year might well be quite exciting. Have you read the statistics ? 2.7 million substances have been pre-registered compared to the expected 200.000. These 2.7 million pre-registrations have been made by 65.000 legal entities and the "true" number of different substances is estimated at some 143.000. This is also interesting since there are only 105.000 on the EINECS list. So there should in theory be 143.000 SIEFs (OSOR). At the beginning of November last year, the authorities were aware of only 1.974 lead registrants. So what's happening about the remaining 141.026 substances ? Depending on the tonnage bands, some of the full registrations need to be ready by the end of this year and, in order to do that, the dossiers need to be completed some 6 months in advance. Four months from now. No data, no market. So if your volumes are big, and your SIEF is not already up and running, you'll probably certainly miss the cut-off. How can the SIEF gather all the data in time ? Are there lab resources available to do the necessary testing? And does Helsinki have the resources to deal with more than 10 times the number of applications they had expected from the beginning ? No data, no market ? No way !

 Posted 18.02.2010