ECHA estimates that around 60,000 registrations for 25,000 substances will be prepared, 3 times more than in 2010 or in 2013. Not only is there a considerable increase in the number of registrations but the type of registrants is very different. As the amounts of substances imported or manufactured per year decrease, so does the size of the companies needing to register. The registrants are therefore expected to be inexperienced and SMEs (small and medium-sized enterprises).
In May 2016, ECHA published statistics on this last REACH registration deadline. We have summed up the main numbers and given our interpretation of these results.
Out of the 60,000 expected dossiers, there have only been 5,773 registrations distributed as shown in the following table per country:
Germany is the top country with the most registrations (1785), 31% of all the European Economic Area, almost 1/3 of all registrations, which is within the normal range when looking at its registration and notification history. The main reason for this is that Germany has one of the biggest chemical industries. The United Kingdom comes in second with 14% and the Netherlands is the third country with the most registrations with 9%.
About 70 % of registrations are for substances produced outside Europe.
Note: the difference between manufacturers and importers is that importers can choose someone who has already registered. Smaller structures that are not manufacturers will also try to buy their products from sellers that are already compliant to avoid the costs.
Most companies wait until the Lead dossier is created to then join as a Member thinking it’ll be easier than creating the whole dossier from scratch.
To Lead or Not to Lead
Although there is more work to do when you are Lead registrant, you don’t have to pay as much for the Letter of Access. Depending on your budget and time you need to weigh the pros and cons of being a Lead or a Member. Indeed, as a Member you can buy a Letter of Access and join the dossier once it is prepared.
Some companies prefer to be a Lead to have more leeway as you can create your own Substance Information Profile (SIP). For Member dossiers you must fit into a SIP, which can be tricky. If you don’t fit into a SIP, then you may have to submit another dossier, which is why being Lead can be an interesting benefit.
In any case the more you wait, the more laboratories are being booked up to conduct necessary tests and the less time you will have to prepare the dossiers, which may cause you to miss the REACH registration deadline.
So, will you Lead?
14.5 % of registrants are SMEs against 85.5 % of Large companies. There are a few potential reasons for such numbers.
The bigger the company, the more it will produce and hence the bigger the tonnages. Sometimes these large companies have many entities and choose to dispatch the tonnages amongst their smaller entities in order for them to avoid registering for the bigger tonnage bands. This could explain why there is wider percentage of large companies registering for this low volume deadline. Another possibility is that large companies often have a budget, which allows them to anticipate and therefore register in advance. Smaller companies can also make the right calculations to fall under the 1 tonne threshold and therefore avoid registering altogether.
What the future holds
Many more registrations are expected as ECHA's statistics from May 2016 show that only 10% have registered out of the forecasted 60,000 registrations to come in 2018. Many more SMEs are also expected to register and they will probably take on the Lead registrant roles more than in the past.
Making registration beneficial
Registration can be a successful investment as it ensures safe use in your company and for your customers. Your company will be considered trustworthy by the authorities and general public, if your data is transparent and of quality so make sure you take the time to make a great dossier. Your data can also be helpful for other regulations worldwide and even reused. Missing the registration deadline means you will not be allowed to manufacture or import substances in Europe. You have about 1,5 years to work on your registration before it’s too late! Consider registration as an investment: Registering means securing business opportunities.
Check our REACH registration services for 2018
EcoMundo is an expert service provider for REACH registration 2018 Our services include:
- REACH compliance Service
- REACH consulting Service
- REACH for non-EU manufacturer
- REACH Registration
- Only Representative (OR) service
- REACH Late pre-registration and inquiry process
- Representation of your interests within the SIEF and/or consortium.
- Negotiation on your behalf and purchase of the Letter of Access (LoA) from the Lead Registrant
- REACH letter of access
- Data exchange and drafting of your REACH IUCLID dossier.
- Submission of your REACH dossier to ECHA and follow-up until acceptance
- Delivery of your REACH certificate
- Regulatory watch when needed
ECHA estimates that around 60,000 registrations for 25,000 substances will be prepared, 3 times more than in 2010 or in 2013. Not only is there a considerable increase in the number of registrations but the type of registrants is very different. As the amounts of substances imported or manufactured per year decrease, so does the size of the companies needing to register. The registrants are therefore expected to be inexperienced and SMEs (small and medium-sized enterprises).
In May 2016, ECHA published statistics on this last REACH registration deadline. We have summed up the main numbers and given our interpretation of these results.
Out of the 60,000 expected dossiers, there have only been 5,773 registrations distributed as shown in the following table per country:
Germany is the top country with the most registrations (1785), 31% of all the European Economic Area, almost 1/3 of all registrations, which is within the normal range when looking at its registration and notification history. The main reason for this is that Germany has one of the biggest chemical industries. The United Kingdom comes in second with 14% and the Netherlands is the third country with the most registrations with 9%.
About 70 % of registrations are for substances produced outside Europe.
Note: the difference between manufacturers and importers is that importers can choose someone who has already registered. Smaller structures that are not manufacturers will also try to buy their products from sellers that are already compliant to avoid the costs.
Most companies wait until the Lead dossier is created to then join as a Member thinking it’ll be easier than creating the whole dossier from scratch.
To Lead or Not to Lead
Although there is more work to do when you are Lead registrant, you don’t have to pay as much for the Letter of Access. Depending on your budget and time you need to weigh the pros and cons of being a Lead or a Member. Indeed, as a Member you can buy a Letter of Access and join the dossier once it is prepared.
Some companies prefer to be a Lead to have more leeway as you can create your own Substance Information Profile (SIP). For Member dossiers you must fit into a SIP, which can be tricky. If you don’t fit into a SIP, then you may have to submit another dossier, which is why being Lead can be an interesting benefit.
In any case the more you wait, the more laboratories are being booked up to conduct necessary tests and the less time you will have to prepare the dossiers, which may cause you to miss the REACH registration deadline.
So, will you Lead?
14.5 % of registrants are SMEs against 85.5 % of Large companies. There are a few potential reasons for such numbers.
The bigger the company, the more it will produce and hence the bigger the tonnages. Sometimes these large companies have many entities and choose to dispatch the tonnages amongst their smaller entities in order for them to avoid registering for the bigger tonnage bands. This could explain why there is wider percentage of large companies registering for this low volume deadline. Another possibility is that large companies often have a budget, which allows them to anticipate and therefore register in advance. Smaller companies can also make the right calculations to fall under the 1 tonne threshold and therefore avoid registering altogether.
What the future holds
Many more registrations are expected as ECHA's statistics from May 2016 show that only 10% have registered out of the forecasted 60,000 registrations to come in 2018. Many more SMEs are also expected to register and they will probably take on the Lead registrant roles more than in the past.
Making registration beneficial
Registration can be a successful investment as it ensures safe use in your company and for your customers. Your company will be considered trustworthy by the authorities and general public, if your data is transparent and of quality so make sure you take the time to make a great dossier. Your data can also be helpful for other regulations worldwide and even reused. Missing the registration deadline means you will not be allowed to manufacture or import substances in Europe. You have about 1,5 years to work on your registration before it’s too late! Consider registration as an investment: Registering means securing business opportunities.
Check our REACH registration services for 2018
EcoMundo is an expert service provider for REACH registration 2018 Our services include:
- REACH compliance Service
- REACH consulting Service
- REACH for non-EU manufacturer
- REACH Registration
- Only Representative (OR) service
- REACH Late pre-registration and inquiry process
- Representation of your interests within the SIEF and/or consortium.
- Negotiation on your behalf and purchase of the Letter of Access (LoA) from the Lead Registrant
- REACH letter of access
- Data exchange and drafting of your REACH IUCLID dossier.
- Submission of your REACH dossier to ECHA and follow-up until acceptance
- Delivery of your REACH certificate
- Regulatory watch when needed
