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REACH Substances due for REACH registration in 2010 - LEAD Only Rep. (SSS)

REACH Substances due for REACH registration in 2010 - LEAD Only Rep. (SSS). REACH- 2010 Substance Details of SSS. > 1000 TPA (tons per annum) - 100 100 – 1000 TPA ( R50/53 & CMR – 1/2) - 41 1-100 TPA (CMR category 1/2 )– 70 Total 211 Intent to register - 106

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REACH Substances due for REACH registration in 2010 - LEAD Only Rep. (SSS)

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  1. REACH Substances due for REACH registration in 2010 - LEAD Only Rep. (SSS)

  2. REACH- 2010 Substance Details of SSS • > 1000 TPA (tons per annum) - 100 • 100 – 1000 TPA (R50/53 & CMR – 1/2) - 41 • 1-100 TPA (CMR category 1/2 )– 70 Total 211 Intent to register - 106 Lead registrant (LR) identified – 69 No LR identified - 37 Consortia existing – 41 No LR, No SFF - 6

  3. 2010 substances divided into various groups • Monomers (27) • Petroleum Distillates (19) • Others (Including TII & natural substances (11) • Organic (97) • Inorganic (49) • Dyes/Pigments (12)

  4. Petroleum Distillates (Applicability of notes) Total such substances of SSS in 2010 deadline – 19 Deadline shifted (based upon Notes) 5 Results awaited- 14 Various Notes • N: Substance is not a carcinogen if the full refining history is known and it can be shown that the substance from which it is produced is not a carcinogen. • L: DMSO extract (measured by IP 346 method) is less than 3.0% • P: substance contains less than 0.1 % w/w benzene (EINECS No 200-753-7)

  5. Cont.... Benefits: If notes are applicable, then the deadline will shift to a later deadline Essential requirement: Valid test results according to suggested method within REACH Another case of interest C.I. Basic Violet 3 with >0.1% of Michler’sKetone (EC No 202-027-5)

  6. Transported Isolated Intermediates (TII) Definition: (about 10) A substance that is put to further chemical processing in Europe and in the chemical reaction that takes place, the transported intermediate completely loses its chemical identity (trace levels of unreacted intermediate may remain) Benefits • Minimal information requirements if tonnage is < 1000 tpa • Information requirements of only Annex VII apply if tonnage is > 1000 tpa Essential criteria to be fulfilled to avail benefit All European buyers that use the TII should give an undertaking that they put the TII to further chemical processing fulfilling all the controlled conditions as mentioned in the REACH regulation

  7. Monomers & Polymer Issue Polymers are exempted within REACH but the monomers have to comply to REACH According to Article 6(3), the manufacturer or importer of a polymer must however submit a registration to the Agency for the monomer substance(s) or any other substance(s), that have not already been registered by an actor up the supply chain, if both the following conditions are met: • (a) the polymer consists of 2% weight by weight (w/w) or more of such monomer substance(s) or other substance(s) in the form of monomeric units and chemically bound substance(s); • (b) the total quantity of such monomer substance(s) or other substance(s) makes up 1 tonne or more per year (the total quantity of monomer or other substance ending up in the final polymer unbound or chemically bound to the polymer)

  8. Exemption for Natural Substances In this case, exemption applies to the following if not chemically modified • Minerals, ores, ore concentrates, raw and processed natural gas, crude oil, coal • Vegetable fats, vegetable oils, vegetable waxes; animal fats, animal oils, animal waxes; fatty acids from C6 to C24 and their potassium, sodium, calcium and magnesium salts In addition, certain chemical substances as listed in Annex IV of the REACH regulation are also exempt from REACH registration as these are considered to cause minimum risk because of their intrinsic properties

  9. Services covered by the OR Maintaining legal status in EU as OR (need OR Agreement in addition to active REACH IT accounts) SIEF representation and communication with LR/SFF/Consortium secy/other SIEF participants (constantly checking SIEF/consortia status, responding REACH IT emails…)- doesn’t include cost of physical meeting which will involve manday cost, travel and stay Providing general consultancy in co-ordination with customers to decide next steps (sending DU templates for sending OR appointment confirmation to customers, meetings, general queries) Tonnage band change (wherever required) Answering to enforcement agencies Legal fee and insurance fee and managing residual legal liabilities Documentation and communication of SIEF codes to appropriate parties Maintaining compliances related documentation Updating about changes in relevant regulatory framework and acting accordingly Data maintenance(customer specific record – technical data/tonnage info/DU info/Uses/substance sameness/LAPD codes/SIEF-LR agreement/consortium agreement/invoice & payment confirmation)

  10. Services NOT covered by the OR This includes: All actual cost payable to third parties like (ECHA/LR/data holders/outside consultants) – these costs should be paid well in advance Detailed legal advice on SIEF/LR/Consortia agreement Fees for IUCLID dossier preparation and submission to ECHA using REACH IT in 2010/2013/2018 Preparation of CSA/CSR Fees for Downstream users Communication - Collection of Use related information using online portal. To be decided jointly with council

  11. Importance of Tonnage Band Tonnage band very important in deciding deadline Tonnage needs to calculated from June 2007 to Dec 2007 (for calendar year 2007) Thereafter it will be Jan to Dec’ 2008 & 2009 However, if the tonnage of > 1000 tpa has been exceeded even once, the deadline will be 30th Nov’ 2010 E.g. If the tonnage exported to Europe is as mentioned below: However, if after subtracting Jan to May’ 2007 tonnage, the tonnage comes out to be 800 or 900 tons then the 2010 deadline can be avoided, as neither the average tonnage has not exceed 1000 nor calendar year tonnage Therefore calculate tonnage band extremely carefully

  12. Data availability & Use Profile Data Availability 67 subs (28 companies) out of total 216 substances Use profile Indian Companies: 60 subs (27 companies) EU buyers: 20 subs (15 companies) % of data availability – 31% % of use profile (Indian companies) – 27% % of use profile (EU buyers) – 9% Very low % data availability & Use profile provided by the companies – These details need to be furnished by the companies to SSS on priority

  13. Substance Sameness Requirements Spectral data 1. Ultraviolet and Visible Absorption Spectroscopy (UV/VIS) 2. Infrared Spectroscopy (IR) 3. Nuclear Magnetic Resonance Spectroscopy (NMR) or Mass spectroscopy (MS) 3 type of spectra’s mandatory Chromatograms 1. Gas Chromatography (GC) or 2. High-Performance Liquid Chromatography (HPLC) Any 1 chromatogram mandatory For inorganic substances 1. X-Ray Diffraction (XRD) or 2. X-Ray Fluorescence (XRF) or 3. Atomic Absorption Spectroscopy (AAS) Any one mandatory

  14. Substance Sameness Requirements (Contd) • Substance name ( CAS Name) • IUPAC Name • CAS No. • EC No (EINECS No) • Molecular formula • Molecular weight / Molecular weight range • Structural formula (Image) • Compositional details (purity of the substance) • Impurity details: Name of Impurity • % of Impurity • CAS no. • EC No. • Molecular Formula • Molecular weight • Structure • Additives details: Name of Impurity • % of Impurity • CAS no. • EC No. • Molecular Formula • Molecular weight • Structure

  15. MSDS Essentials • 16 point MSDS Mandatory Hazards identification should precede compositional information (as per the REACH format) Substances or Preparations for which a SDS is required: • The substance on its own or in preparation meets the criteria for classification as dangerous under Directive 67/548/EEC or Directive 1999/45/EC, or • It is PBT or vPvB substance, or • It is included in the candidate list of substances which may be subjected to authorization. SDS is required at the request of a recipient • At least one substance posing human health or environmental hazards in an individual concentration of 1% by weight for non-gaseous preparations and 0.2% by volume for gaseous preparations; or • At least one SVHC in an individual concentration of 0.1% by weight for non-gaseous preparations; or • A substance for which there are community workplace exposure limits

  16. REACH registration costs (per substance) Approximate Considering large company & joint submission

  17. REACH registration costs (per substance) Considering medium company & joint submission

  18. REACH registration costs (per substance) Considering small company & joint submission

  19. REACH registration costs (per substance) Considering micro company & joint submission

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