Priorities for 2011

• The time limit for the first registration expired at the end of 2010. In accordance with the strategy on sanctions, any failure to register enforcers will punish companies from 1 January 2011 in accordance with the principle of ‘no data: no market'.
• Special attention will be paid to checking of registrations performed on: quality of registration dossiers (article 20.2 decision of ECHA on Quality Observation Letter (QOBL)), obligatory sharing of information during the registration process, Process and product orientated R&D (PPORD¹)-registrations, late pre-registrations, testing proposals and the registration of intermediate (on-site and transported isolated) substances.
• Compliance with the duty to communicate information on Substances of very high concern (SVHC) in articles (article 33 of REACH). How are distributors communicating information and answering requests from consumers about SVHC.
• The CLP-obligation (notification C&L) for substances, that applies as of 3 January 2011 will be checked.
• Use of information from the SDS in the health and safety policy.
• The enforcement strategy guidelines for REACH state that targeting the supply chain for certain (environmentally) hazardous substances can be an effective means of improving compliance throughout the whole chain. The enforcers will conduct a pilot in 2011.

See the page Publications for an overview of the controls in 2011. This document lists the type of inspection performed for each type of business. A summary of the enforcement strategy is also available on the page Publications (in Dutch only).

¹Substances manufactured or imported for the purposes of product and process orientated research and development.