ECHA has released a new “nutshell” guidance on identification/naming of substances for REACH.
Don’t assume the old conventions of EINECS or TSCA apply. There are new naming conventions and lots of controversy over whether or not substances are “the same” for REACH registration purposes. The SIEFs spend significant time deciding whether they need one or more dossiers on what was believed to be the same marketed chemical. Hence ECHA’s guidance to not simply rely on the quick look-up of pre-registered and registered chemicals to see if you’re covered. Contact your supplier.
A substance is defined in REACH by Article 3 and in CLP by Article 2 as:
“a chemical element and its compounds in the natural state or obtained by any manufacturing process, including any additive necessary to preserve its stability and any impurity deriving from the process used, but excluding any solvent which may be separated without affecting the stability of the substance or changing its composition”.
Go to the full guidance for details and examples. ECHA has created new schema for naming chemicals: mono-constituent substances (>80% a single structure, plus physical form for minerals), multi-constituent substances (known structures each 10- 80%), and 4 subtypes of UVCBs. They are assigning new EC numbers to some "substances" as a result of this new guidance.
ECHA has a whole set of "nutshell" guidance that are worth reviewing: http://guidance.echa.europa.eu/guidance2_en.htm
Contact EHS Strategies, Inc. for assistance.
- Tags:
- REACH