Guide for Early Registration of Nickel Metal and Nickel Sulphate
The Nickel Consortia has decided to register Nickel Metal and Nickel Sulphate a few months before the recommended deadline.
The Registration deadline for Lead Registrant (LR) has been debated at the ECHA and Commission level during the first months of 2009.
Due to uncertainties in legal interpretation of art. 21.3, ECHA and the Commission recommend to LR to register before September 30th, 2010, in order to avoid the risk to see production/import of Registrants interrupted between December 2010 and February 2011.
The expertise that Nickel Consortia had in the past with completion of Risk Assessment Dossier has clearly identified the need for sufficient time before submission of the dossier. Therefore it is certainly beneficial to have some of the key Nickel substances registered.
Benefits of submitting two Registration files beginning of next year are:
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Test the internal review of the Registration file on time
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Test the REACH-IT system in front of huge mega files (~70Mb)
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Balance the workload in 2010
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Ensure availability of the metal file for alloys assessment.
What would be the consequences for SIEF members?
SIEF members who need to register Nickel Metal and Ni Sulphate by the first registration dead-line are invited to contact, as soon as possible, the Nickel REACH Consortia to take part of the Joint Submission.
Of course, the legal registration dead-line remains the same and co-registrants will be able to join the submission at any time.
However, the Nickel REACH Consortia Secretariat suggest to companies interested in the registration of those Nickel substances, to take part of the Joint Submission as soon as possible.
This will ensure companies a good compliance with the REACH Regulation in advance.
Key dates for Nickel Metal and Nickel Sulphate SIEF members:
April 2010: Registration of Ni Metal and Ni Sulphate by the LR
From early May 2010 to end of November 30th 2010: Individual Registration for Nickel Metal and Nickel Sulphate.
