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It is key for the EU to clarify the key points of CoRAP substance assessment for member States to contact registrants in a timely manner
ChemicalsEU REACH
Apr. 16th, 2024
At a workshop on substance assessment held in Helsinki on 4-5 June 2012, EU Member State law enforcement authorities, ECHA and stakeholder representatives agreed that Member States should contact the registrant as early as possible during the CoRAP substance assessment process.

  At a workshop on substance assessment held in Helsinki on 4-5 June 2012, EU Member State law enforcement authorities, ECHA and stakeholder representatives agreed that Member States should contact the registrant as early as possible during the CoRAP substance assessment process.

The EU Community Rolling Action Plan (CoRAP) regularly selects substances that may be harmful to human health or the environment and promotes the safe management of substances through subsequent assessments to identify the risks of substances. It should be emphasized that the inclusion of substances in the CoRAP assessment list does not mean that they will be restricted or prohibited, but only for the purpose of identifying their risks through the assessment, and subsequent management measures will be determined based on the results of the assessment. It may be that the management measures already in place for the substance are sufficient, or it may be that the substance requires new risk management measures.

The first CoRAP substances were officially released on 29 February 2012 and will need to be evaluated by different member States between 2012 and 2014. Regarding the evaluation of substances, the workshop agreed that the evaluation member States should contact the registrant of the substance as early as possible, and formed some generally recognized provisions:

Once a Member State determines that a substance is to be assessed, the Member State shall contact the lead registrant of the substance as soon as possible;

All registrants of

substances need to identify through dialogue one of the registrants (generally the lead registrant) to communicate and communicate with the assessment Member State;

The parties may only exchange technical information about the substance during the evaluation of the substance;

Due to the strict time control of the evaluation of substances, the registrant needs to complete the update of the registration dossier before the evaluation begins, otherwise the updated content will not be taken into account in the evaluation of substances. Of course, if it is true that the update of the dossier cannot be completed before the start of the assessment, the lead registrant will need to contact the assessment Member State in advance to determine the timing and content of the update.

Delegates at the workshop also agreed that in the public comment step of the substance evaluation decision stage, all registrants of the same substance should unify their views and submit a single comment. In addition, it is considered that the CoRAP substance screening criteria adopted in May 2011 do not need to be revised, and ECHA, Member States and stakeholders will use the criteria with further flexibility.
 
Because the substances included in CoRAP have to go through a rigorous substance evaluation process, which will bring great risks to the relevant enterprises, enterprises must not hold the idea that the registration number has been completed, but should actively pay attention to the evaluation process of the substance, in order to provide the necessary data in a timely manner when the ECAH requests further information. To ensure that their own trade is not affected.
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