The EU’s EC Inventory maintained under the Registration, Evaluation, Authorisation, and Restriction of Chemicals (REACH) framework is the world’s largest inventory and includes 106,212 substances. REACH adopts a “no data, no market” principle, requiring all chemicals on the market to be registered with the European Chemicals Agency (ECHA).
During the transition period from 2008 to 2018, new substances were required to be registered before being placed on the market, while existing substances benefited from a transitional period, depending on the annual tonnage band. As of June 2018, any substance not registered cannot be marketed in the EU. The EC Inventory emphasizes comprehensive data collection, including hazard classification, safety data sheets, and use information, making it a global benchmark for chemicals regulation.
From January 1, 2020, all substances (existing or new) will have to go through an inquiry process with ECHA. Companies will provide the substance “fingerprint” and ECHA will review the inquiry and determine if the substance is already registered or not. If registered, companies are directed to the Lead Registrant to facilitate the registration process. For unregistered substances, the inquiring company must prepare a technical dossier and complete the registration, before being able to place the substance on the EU market. This process can be time-consuming, depending on the toxicity and ecotoxicity data available and the time needed to acquire or complete studies for missing data. It is also very costly, as data costs are not shared with other registrants, so a single registrant has to bear the full cost.
The European Union’s REACH framework allows registrants to claim confidentiality for specific details, such as the exact chemical identity or intended uses, during the registration process. The European Chemicals Agency (ECHA) evaluates these claims to ensure that they are justified. REACH maintains a strong emphasis on transparency, requiring companies to disclose essential hazard information and ensuring access to sufficient data for risk assessment.
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