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REACH Authorisation
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Timeline

1. Identification of relevant SVHC

Anticipation phase

Industry needs to make an optimal use of this phase.
  • Set-up of warning system in companies (inventory, assessment of criticality and risks)
  • Consortia to keep Registration up-to-date and refine assessments when needed
  • Establishment of relevant value chain contacts
  • Preparatory work: data gap analysis, own RMO with proposals for alternative Risk Management Measures

Reaction phase

Industry must be equipped to react in a timely and relevant manner
Toward ECHA and Member States:
  • Input to official RMO
  • Input to Public Consultation
  • Participation in public and private forums
In the value chain:
  • Communication
  • Mobilisation
  • Investing in shared understanding and expertise
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2. Prioritisation

Anticipation phase

Industry must to keep focussed as the proposal for prioritisation may take years instead of months

Toward ECHA and Member States:
  • Keeping Registration and RMO-relevant information up-todate
In the value chain:
  • Companies to have clear strategy regarding Authorisation
  • Start of groundwork to be prepared to address challenge of having to apply for Authorisation (organisational aspects, content of the Application for Authorisation)
  • Communication in value chain
Reaction phase
Toward ECHA and Member States:
  • Participation in Public Consultation
In the value chain:
  • Preparation for the Authorisation process (preparation and agreement on the cooperation framework, preparing to address legal and practical challenges, preparing the work plan for an Application for Authorisation)
  • Communication
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3. Authorisation

Industry's efforts to get organised and prepared months and years ahead should facilitate the process, which will be very challenging.
A lot of work needs to be performed and many critical decisions need to be taken in a very short time.

Preparation of Application

Implementation of the preparatory work:
  • Launch of operations of the structures to support or lead the preparatory work
  • Building on the strategies prepared prepared at earlier stage:
  • Bringing together the constituent blocks of the Application dossier
  • Decision on uses to apply for (collectively or separately)
  • Preparation of an Application that is sound and clear
  • Maintaining trust and adaptability to unforeseen challenges
  • Preparation for challenges during the examination of the Applications: alternatives, weaknesses of arguments and data

Defence of Application

This phase will typically involve a smaller team of highly devoted experts
  • Anticipation of very technical questions
  • Maintaining the capacity to react quickly to information requests
  • Briefing Member States
  • Keeping channels of communication open with the European Commission

Compliance

Anticipating a positive decision, the future needs to be prepared Applicants separately:
  • Communication to value chain
  • Implementation of Substitution Plan or R&D plan Applicants collectively:
  • Assessment of the process as it unfolded, taking in learning lessons
  • Keeping alive the value chain dynamics and contacts
  • Start planning for the review process (maybe in 4 years!)
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