Currently, the REACH-IT has notified the implicated 574 registrants, calling for re-checking and updating of dossiers within 3 months to ensure the correctness of them. The ECHA will manage auditing again 3 months later and take further regulatory step to all the unqualified dossiers. It is mostly likely that ECHA, according to the article 10 of REACH regulation, will require the affected registrants to provide detailed information more than usual over general registration purpose.

In 2010 and 2011, ECHA has already found hundreds of problematic registration dossiers of intermediate during the conformity assessment and required further check and update of the registration. The registrants with problematic dossiers have mostly updated the dossiers. Some of them even updated the entire dossier of the intermediate registration dossiers while others considered whether its dossiers were compliant with the Article 17 or 18 of the REACH regulation. Meanwhile, there are also some cases where on-site auditing is still needed so as to decide whether further regulatory measures have to be imposed.

Intermediate under strictly controlled condition

The intermediate under strictly controlled condition is a relatively special category in REACH registration. Compared with substance in general use, the REACH regulation stipulates that part of the registration data of intermediate can enjoy exemption so that the data fee can be reduced, according to the Article18(2) of REACH regulation. Plus the huge financiallyfavorable measure towards the administration fee of intermediate, the total cost of intermediate registration usually accounts for a little fraction of that registered for general use. The specific details are as follow:

–the administration fee: 1200 EURO for joint registration, 1600 for individual registration;

–the CSR is not required to all tonnage bands;

–the data requirement for intermediate registration only exceeds to the data of general substance under the tonnage band of 1-10 ton per year.

Further details about intermediate registration in EU REACH, please visit ECHA’s official website. You may also contact us for professional advice on registration preparation.

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