REACH - Final draft RIP 3.4

Orgalime Comments

In the context of the ongoing stakeholder’s consultation on the final draft guidance document on pre-registration and data sharing (RIP 3.4), Orgalime wishes to provide the following comments.

Orgalime is concerned with the ambiguous wording of the last sentence of point 3.7 of the above mentioned RIP, which reads as follows:

“What if the deadline for pre-registration is not met? If a company fails (or does not wish) to pre-register within the applicable deadline (i.e.in most cases 1 December 2008), it will have to suspend its activities involving the substances concerned and register them without delay. In addition it should be remembered that in this case the registrant will also have to enquire at the ECHA if a registration for the substance has been made. All manufacturing, placing on the market and use of such substances between the start of the pre-registration deadline (i.e. in most cases 1 June 2008) and the date of suspension of activities may be subject to penalties according to national law”.