Summary of what is required for pure metals and for metals contained within alloys.
Pure metals, such as tin, are substances under REACH and require full substance registration. Further information on the REACH status of some of the non-ferrous metals can be found here.
Under REACH an alloy is defined as ‘a metallic material, homogenous on the macroscopic scale, consisting of two or more elements so combined that they cannot be readily separated by mechanical means.’ In most instances alloys are considered to be preparations, albeit special ones, as it has been recognised that they 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. Further information on the pre-registration and registration requirements for imported alloys can be found here.
Ores and Concentrates
Minerals, ores, and ore concentrates are exempt from registration unless they have been chemically modified. They are also exempted from the downstream user and evaluation obligations of REACH. However, companies that place hazardous ores and ore concentrates on the market must assess the hazardous properties of those materials and communicate them down the supply chain with a Safety Data Sheet (SDS) advising users on the measures required for adequate management of risk to human health and the environment. Manufacturers and importers of ores, and ore concentrates, must also notify the Agency of their commonly agreed classification and labelling before 1 December 2010. Further information on ores, ore concentrates and REACH can be found here.
Slags and residues
Slags that are considered as by-products on the basis of the criteria cited in the 2007 Commission Guidance Document must comply with the requirements of REACH i.e. if:
- The intended use of the material is lawful
- The material is deliberately produced
- The use of the material is certain
- The material is ready for use without further processing
- The material is an integral part of the production process
Most of the slags have an EINECS/CAS number and therefore can be (pre-) registered; in most cases, registration as a substance with Unknown or Variable Compossition or Biocidal (UVCB) will be most appropriate due to the variable composition of most slags and residues. The common approach in registering slags and residues amongst the metals industry will be to have ‘typical’ slags tested and then read-across, through leaching tests and bridging principles, to other materials. In most cases it is likely to be possible to produce one registration dossier with a wide spectrum of compositions covered.