Data Analysis of REACH Registration from 2010-2018

The 10-year registration period for existing chemicals is now completed following the last REACH registration deadline on 31 May 2018. A total of 21551 substances are registered. However, the coming of the last registration deadline does not mean the close of the REACH registration, enterprises still face various works, such as dossier completeness check, dossier evaluation, new substance registration, ESDS authoring, etc.

Substance and registrations

Since 2008, 13620 companies have submitted 88319 registration dossiers in all tonnages to ECHA. 82874 of these were found complete and companies have received their registration numbers. 5445 registrations are still being processed, as they were submitted close to the 31 May 2018 deadline.

Overall, the submitted registrations cover 21551 substances, which account for about 20% substances listed in the EU existing substances list. Companies have registered fewer substances than estimated in 2006 by the European Commission (~30000 substances, accounting for 30% of the substances listed in the EU existing substances list). There might be several reasons, but what is clear is that many companies have rationalised their substance portfolios making their registration decisions based on business analysis. They have, therefore, registered fewer substances than initially planned when they pre-registered. The impact of this in the chemicals’ supply chains will only be clearer by the end of the year.

NB: The numbers for registrations and substances are different as one substance can be registered by more than one registrant (company). Each registrant must submit their own registration, though companies work together to share data on the substance.

EU-based enterprises VS Non-EU manufacturers

23 % of the registrations were made by only representatives on behalf of a non-EU company, while 38 % were made by importers (some of which may also be manufacturers). The rest of the registrations were submitted by EU/EEA manufacturers.

Registrations were received from companies in all 28 EU Member States and three European Economic Area (EEA) countries, with the largest shares coming from Germany (25 %), the United Kingdom (14 %) and France (10 %).

The Registration status of non-EU enterprises

The top five non-EU countries from which companies submitted their registrations through only representatives are the USA (27%), China (15%), Japan (14%), India (12%) and Switzerland (6%).

Breakdown by the registrants’ company sizes

Among all registrations, 18 % of all registrations were submitted by micro, small or medium-sized companies (SMEs); 82 % came from large companies. The table below shows a breakdown of the number of registrations by company size (micro, small, medium-sized or large company) as indicated by the companies:

Registrations by company size	Registrations submitted	Registration completed
Registrations by large companies	72 559	68 348
Registrations by SMEs	11 020	9 786
Medium-sized companies	6 264	5 551
Small –sized companies	3 524	3 114
Micro-sized companies	1 232	1 121
Registrations by companies with undefined company size	4 740	4 740
Total	88 319	82 874

Breakdown of registrations by tonnage band

The table below shows a breakdown of the number of registrations and substances by tonnage bands, intermediates under strictly controlled conditions and NONS:

Tonnage	Registrations completed	Substances (in completed registrations)	Registrations still being processed
1 000 tonnes per year and more	20 113	2 278	101
100 - 1 000 tonnes per year	12 489	3 517	304
10 - 100 tonnes per year	11 080	3 957	1 849
1 - 10 tonnes per year	14 685	5 908	2 369
Intermediates (under strictly controlled conditions)	14 549	7 675	822
NONS registrations	9 958	5 293	0
Total	82 874	-	5 445

Top 10 EU/EEA countries: registrations and substances:

The table below shows the top 10 countries in the 28 EU Member States and the European Economic Area countries (Norway, Iceland and Liechtenstein) in terms of number of registrations.

REACH registrations after May 2018

Now that the 10-year transitional period is over, any company manufacturing or importing a chemical in amounts of more than one tonne per year needs to have it registered under REACH before placing it on the EU/EEA market. Also, the companies that have completed their registrations need to keep the information up to date, to reflect, for example, the correct production volume, new uses, and the most recent safe use advice.

Future works

Currently ECHA masters large amounts of chemical information. This kind of information will be used to protect citizens and the environment from the risks posed by chemicals. ECHA, the EU Member States and the European Commission will use the increased knowledge to take action where necessary, for example, by restricting or authorising certain uses of chemicals.

ECHA has until 31 August 2018 to check the completeness of all submitted registrations and either assign a registration number or inform companies if information is missing from their dossiers. In most of the pending cases, ECHA is checking the completeness of the information submitted against the information required by law or waiting for the companies’ registration fees to be paid.

Registration is just the start. Companies need to, together with the OR, follow developments closely and keep the information on their chemicals up to date.

Reference

21551 chemicals on EU market now registered

REACH registrations since 2008

REACH 2018 results