ECHA decision letters delay
  • Andrey ChervyakovAndrey Chervyakov
    Dear colleagues, dear readers.

    Let me quickly describe a stalemate situation we are in and kindly ask for your opinion.

    My company registered 95 percent of the substances under REACH as a part of joint submission.

    In 2010 there was made a decision to start export of two more substances to EU, so we filed the inquiry and prepared the dossier for registration. The inquiries were submitted in the end of September and still we never received a decision letter from ECHA. That’s the only step that prevents registration for our substances, the dossiers are already prepared.

    ECHA only telling us they will do their best to facilitate processing of our inquiry…

    We kindly ask you to share your experience or your recommendations to this situation.
  • Chris BraunChris Braun
    I would suggest that your lawyer send them a letter telling them that they will be held responsible for all loss of company income due to this delay.
    Chris
  • Steffen ErlerSteffen Erler

    My understanding is that you can still submit and complete a registration without a response, as long as you make sure to meet requirements of data sharing and joint submission. In other words, the completeness check at ECHA may not necessarily fail without a formal inquiry number. This may therefore work in certain cases, such as where there is already a consortium available and this is publicly known. The registrant can then become part of a relevant joint submission and ensure compliance with necessary data-sharing. But I have not (yet) tried this in practice. Any comments are appreciated.

  • Peter DOUBENPeter DOUBEN
    We have experienced the same issue. In the end, and to cut a long story short, submitted our client's dossier as a co-registrant meeting the datasharing and joint submission requirements of the legislation. Our website: www.reachwise.eu where you can contact us, or directly through info[no spam]@reachwise.eu
  • Bettina MachBettina Mach
    Dear Andrey,
    we faced the same situation some years ago in 2008.
    After waiting several weeks for a response from ECHA I tried to register
    without having the inquiry number. That was impossible due to the
    business rules. So, we had to wait, until ECHA sent us the inquiry
    number. That can unfortunately take several weeks or month.
    Best regards
    Bettina Mach
    Dr. Mach Chemical Compliance & Competence
    www.mach-chemguide.com
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