Manufacturers and importers of inorganic tin chemicals (in quantities of 1 tonne or more each year) are responsible for registering dossiers of information about those chemicals with the European Chemicals Agency. In order to relieve some of the burden, companies are being encouraged to work together and share the costs.
Inorganic tin chemicals groupings
In REACH, there is a general obligation to use any available test data on the substances themselves. However, if no test data are available, the process of "read-across" may be used. To this end, the Chemicals Agency on-line registration system will require a registrant to point out other similar compounds to the one being registered which should be considered for read-across. This aims at minimising further testing of compounds which are currently lacking the eco-toxicological and toxicological information which will be required for substance registration under REACH.
Having performed a data gap analysis on existing information for the inorganic tin compounds ITRI has found that there is very little data available on inorganic tin compounds, this emphasises the need to consider the grouping of the inorganic tin chemicals for read-across purposes.
By considering all of the information available ITRI are able to work with the tin chemicals industry to agree on, and assist in, the formation of an industry wide consortium for the inorganic tin chemicals.
Organotins will be dealt with separately by different consortia. Please visit the following website for further information: http://www.reachcentrum.eu/en/consortium-management/consortia-under-reach/organotin-reach-consortium.aspx
In REACH, alloys are specifically identified as "special preparations", this is because it has been recognised that metallic alloys usually have properties that are distinctive from those of their constituent metals. As REACH does not permit the registration of preparations it is likely that in the vast majority of cases, treating the components of alloys as substances in a preparation will be the most appropriate way for companies to fulfil their duties under REACH.
Manufacturers of melted alloys should determine whether the substances in their alloys have been registered. If so, they are downstream users and, as such, are not required to make a registration. If however a substance in their alloy has not been registered, they may be obliged to make a registration if they wish to continue to use the substance in their alloy.
Manufacturers and importers of smelted alloys have two options for registration and should consider each carefully. They may choose to register in line with that of melted alloys or, alternatively, may wish to register their alloy as a multi-constituent substance. Each case will have to be considered on its merits.