Dancet : les sociétés n’enregistrent pas correctement leurs produits chimiques[en] 

Many companies not only submit incomplete REACH registration dossiers, but they also try to list several substances in one file and fail to be precise enough over the exact composition of their substances, Dancet said.

While the review process of the first REACH registrations is still underway, ECHA has already identified some systemic problems in the dossiers submitted.

One of the most important lessons learnt was the need to prevent companies from registering many substances in one file, Dancet told EurActiv. "There can only be a registration for one substance. You cannot take a group of substances and register them as one," he said. 

Furthermore, not all registrations so far have complied "with all technical rules," said Dancet. He said companies did not seem to understand "the business rules we apply in checking the files". 

Dancet also stressed that many of the dossiers were not good enough and needed to be sent back, because companies were having difficulty writing down the exact composition of a substance, and thus "don't clearly distinguish which substances we are talking about". 

Meanwhile, ECHA is urging companies to establish so-called 'Substance Information Exchange Forums' (SIEFs ) to share information, avoid double testing and allow the lead registrants to prepare joint registrations. 

The agency received around 2.7 million pre-registrations - some twenty times more than expected by the Commission - corresponding to over 150,000 different substances. For 55,000 or so distinct substances, the pre-registrants indicated a registration deadline in 2010. 

However, according to ECHA, many of these 55,000 substances will not be registered, citing a number of reasons including "possible mistakes or double pre-registrations". In its planning, ECHA thus uses the estimates done by the European Commission and expects around 10,000 registrations to have been completed by 2010. 

While 80% of all SIEFs feature between 10 and 99 companies, less than 10% of these forums have appointed lead registrants so far.

"It is very important for companies to actually organise themselves" to make sure that the lead registrant files the dossier "not just a few days in advance," to make sure that ECHA is able to check it "before the others register," Dancet said. 

He underlined that companies "have every interest in making sure that the timing of the joint registration is really well coordinated". Indeed, if the dossier is technically incomplete, companies "will have to withdraw their products from the market until they have made a complete registration," said Dancet. 

As for overall enforcement of REACH legislation and implementation rules, "the enforcement laws can be extremely difficult" as they are national and thus "not necessarily the same," said Dancet. What constitutes a grave mistake or non-compliance in one country may only be average non-compliance in another, he added.

In addition, not all member states have adopted enforcement rules yet. The European Commission is still awaiting notification of national REACH enforcement provisions from Austria, Belgium, Spain, Italy, Luxembourg, Latvia and Portugal. 

To read the interview in full, please click here.