After one and a half years have passed since the United Kingdom declared its intention to leave the European Union, there is still much uncertainty in the air about Brexit and its scenarios. It is completely open whether there will be Brexit with transition phase of 21 months (March 2019 - December 2020) or not, since a transition phase will only be accepted if a comprehensive withdrawal agreement is in place.
Michel Barnier, the Chief Negotiator of the EU, recently asked companies in the EU to accelerate their preparations for the Brexit, be it a structured or unstructured exit. He encouraged industry to ensure that its value chains between the EU and the UK are made Brexit-safe. The UK government, in its turn, has started to publish no-deal EU withdrawal guidance for the chemical industry. Read more here.

Who/what is concerned?

EU REACH registrations:

  • Solution for substances that were REACH registered by UK-based Only Representatives (OR) - transfer the OR role to SCC!
    No worries, OR transfers are “business as usual” for SCC and therefore can be done cost-effectively!
  • Solution for UK importer or manufacturer registrations – registration e.g. by SCC as OR or by an EU importer / downstream user supported by SCC.
    Rely on us, SCC has nearly one decade of experience in this field of REACH registration!

Substances marketed in the UK:

  • Solution for such substances that need to be registered according to new regulation (under preparation) in the UK for continued supply - UK registration via SCC in collaboration with its experienced UK-based partner consultant!
  • Judging from our experience,  project costs and agency fees should be in a similar range as for generation and submission of an EU Member dossier for REACH.

What is your degree of preparedness for the Brexit? Do not hesitate to This email address is being protected from spambots. You need JavaScript enabled to view it. if you want to enhance your ability to stay agile and to secure your supply chains in Europe!

Chemicals/REACH

Lorem ipsum dolor sit amet, consetetur sadipscing elitr, sed diam nonumy eirmod tempor invidunt ut labore et dolore magna aliquyam erat, sed diam voluptua. At vero eos et accusam et justo duo dolores et ea rebum. Stet clita kasd gubergren, no sea takimata sanctus est Lorem ipsum dolor sit amet.

Lorem ipsum dolor sit amet, consetetur sadipscing elitr, sed diam nonumy eirmod tempor invidunt ut labore et dolore magna aliquyam erat, sed diam voluptua. At vero eos et accusam et justo duo dolores et ea rebum. Stet clita kasd gubergren, no sea takimata sanctus est Lorem ipsum dolor sit amet.

Consortia management and SIEF work is still required after the last REACH phase-in deadline of May 2018.

In your role as lead registrant for a substance you may need to lead and run a SIEF or consortium, but lack the experience or the resources to do so well. We are experienced in efficiently managing consortia and SIEFs on behalf of our customers and have enjoyed high industry trust for many years.

Our spectrum of services ranges from setting up consortia/SIEFs and handling trust accounts to data collection and archiving, and handling confidentiality and data compensation issues. We can also represent clients in consortia and SIEFs managed by a third party and cover all technical, scientific and regulatory aspects.

New members may wish to join the SIEF or consortium, LoAs may need to be calculated and issued or the cost shares for new studies performed on request by ECHA may need to be calculated. Since SIEFs and consortia must remain operational, it is essential that they have their contracts checked for validity after the registration deadline of May 2018. Let us handle the entire consortia and SIEF management for you. We have the expertise you need.

We have no laboratories of our own and are thus free to contract all necessary studies out to the laboratories best suited to meet your regulatory needs. Through partnerships with international CLP-certified laboratories we can offer you high-quality studies with independent monitoring by SCC at favourable conditions.

We monitor the performance of the studies (study monitoring) to guarantee full compliance with regulatory and scientific requirements and standards. We can also support your in-house laboratory with respect to study planning, monitoring and reporting.

Planning and monitoring studies on physico-chemical properties, analytical methods (method development and validation), toxicology, residues as well as environmental fate and ecotoxicology are done on a routine basis.

In addition, we have a wealth of experience in designing, monitoring and evaluating non-standard studies in the chemicals sector, such as toxicokinetic and dermal-absorption studies as well as workplace exposure studies / operator exposure studies.

Study monitoring is usually part of a registration process; however, it can also be done as a stand-alone project.

 

 

EU REACH – our core competence

We have proven expertise in the registration of chemicals:

Since REACH entered into force in 2007 we have prepared more than 500 lead dossiers for phase-in and non-phase-in substances. We handled more than 50 PPORD notifications, far more than 1,000 (late) pre-registrations and well over 1,000 CLP notifications.

We have long-standing experience with intelligent testing strategies, read-across, data bridging, QSAR, group/category approaches, PBT/vPvB assessment as well as planning and monitoring all dossier-relevant studies. By cooperating with international GLP-certified laboratories, we are able to offer you testing packages at highly competitive prices, including close monitoring by SCC.

We cover all types of substance, such as mono and multi-constituent substances and UVCBs, both inorganic and organic.

It goes without saying that we have excellent command of all regulatory tools and models such as IUCLID as well as the REACH-IT and risk-assessment tools (Chesar, EASYTRA, ConsExpo).

We support clients through evaluation processes handled by ECHA and Member States (CoRAP, SVHC, CLH dossiers).

In summary, we provide the full range of REACH and CLP services, covering organisational, regulatory, technical and scientific aspects.

REACH did not stop after the last phase-in deadline passed in May 2018. It is your legal responsibility to keep your submitted dossier up to date. SCC highly recommends that you regularly review your dossiers to be in line with the latest ECHA requirements. Updating your dossier will in many cases avoid it being shortlisted or prioritized for compliance checks and substance evaluation.

ECHA recently announced that, from 2019 onwards, they will reduce their support when it comes to compliance checks of dossiers: Compliance checks will not be announced upfront anymore and your opportunities to contact ECHA directly will be reduced. Considering this, an experienced partner is required when defending your submitted dossiers.

Let SCC be your partner: we have the knowledge and experience to ensure you always stay up to date and on top of things.

 

Find out more about activities under REACH after May 2018