Company-specific information lengthens process
Each of these three documents is extensive, can comprise more than 100 pages and, for logical reasons, should be written in legal, watertight English. The documents begin with measurements indicating emissions levels of production processes and how adversely employees are affected by these. However, the Analysis of Alternatives (AoA), a product-specific investigation of the possible alternative substances and procedures to chromium VI as a means of production, is highly time-consuming and must be carried out separately for each use. The IPA team has collected extensive data on this and carried out specific examinations of coating properties.
Metzner says: "Once all that is done, a specialized consultancy firm must formulate and submit the application to the ECHA, a process which, in my experience, takes another year." It can then take another two years for the European Commission to grant REACh registration upon the recommendation of the ECHA. Metzner adds: "Therefore, it is of the utmost importance to start the specific authorization process now, so that everything is ready by the time the presumptive transition period for the current collective applications is due to come to an end."
It is worth the effort: Summarizing his previous experiences with REACh registration applications, Metzner comments: "The more detailed and specific the application, the longer the process for REACh registration lasts".
Expediency of single applications unclear
However, it is unclear whether large-scale collective applications will remain logical in future due to an inevitable lack of company-specific information in this regard. Metzner recommends individual applications, pointing out that "long-term authorizations are market-decisive for companies in the electroplating industry and coating end users."