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REACH Authorisation
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Application milestones

► Latest Application Date (LAD)

A date is set for each substance included in Annex XIV, at least 18 months before the sunset date. Applications for Authorisation must be submitted by this date if the applicant wishes to continue to use the substance or place it on the market for certain uses after the sunset date and until a decision on the Application for Authorisation is taken.

Latest application date and sunset date are the outcome of a series of considerations and interactions between stakeholders. Industry has different channels to influence the choice of these dates, such as through the Public Consultation related to the prioritisation discussed in the previous chapter, advocacy with Member States and the European Commission.

When a supply chain is very complex, including many companies and especially SMEs, it is possible that the sunset date and latest application date can be extended by up to six months or more. For the phthalates, the sunset dates were set between 42 and 54 months. The Chromium VI supply chain was also able to obtain a significantly longer period for introducing its application as it had convinced the EU that time was too short for all SMEs involved to get a fair chance of introducing an application.

Usual application and sunset deadlines:
LAD: Date of entry into force (publication in Official Journal) + 18 months or a date set by the European Commission, whichever is the latest…
SSD: Date of entry into force (publication in Official Journal) + 36 months or a date set by the European Commission, whichever is the latest…

Do look for extended deadlines and have solid arguments for obtaining them.Getting organised in a value chain may prove very challenging…

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