FAQ
In this section you will find answers to the most relevant questions identified in the metals industry and in the EU inorganics sector. Answers are provided by a panel of experts from the metals industry and from the REACH Alliance, continually discussing the questions emerging most frequently in the metals and inorganic industry. You also can forward questions with relevance for companies or sectors in the metals industry, which will then be discussed by the expert panel before an answer is provided and published on the system.
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- Title
- Labeling
- Can my substance label remain under DSD even if I have classified in CLP until December 2010?
- Is there a maximum number of pictograms and precautionary statements on labels?
- What are the pictograms for CMR categories 1A and 1B compared to category 2?
- With the introduction of the CLP guidelines will I have to re-label all of my existing stocks?
- Data & Information
- How much time do I have to change the classification of a substance or mixture upon development of new toxicity/ecotoxicity information that changes the classification?
- Is physico-chemistry testing needed if no reliable data is available?
- Is there an outlined methodology for using read-across?
- What is bridging? And how important is it?
- What is the minimum phys-chemistry data for CSA/CSR (REACH)?
- Classification
- Are massive metals to be classified under STOT?
- Are nanomaterials/particles need to be classified and labelled since no ruling exists as yet?
- Are there community wide classifications now that the DSD List Annex 6 is deleted?
- Can you simply use the CLP conversion table to classify your substances, without going back to original data?
- Do I need to reference to DPD or DSD classifications If I classify and label under CLP after December 2010?
- Do mixtures have to be notified?
- Does registration under REACH before December 1, 2010 have to be accompanied by classification according to CLP and NOT according to DSD?
- Is it correct that only substances in quantities of 1000t or more need to be notified?
- Once a metal is classified, does it always need to have a label?
- Who do CLP obligations apply to?
- Who is the leader for the classification under CLP?
- Will self classification be a uniform process?
- Pre-Registration
- Could a Consortium make a pre-registration for its members?
- Does pre-registration finally decide on the status of the substance?
- Does the EU provide any documents /templates for pre-registration
- How do we know into which tonnage band a substance we use or produce in the EU will fall?
- Should a substance that does not have to be registered (e.g. coal) be pre-registered?
- What will happen if we miss pre-registration? Can we proceed straight to registration? Can a company still market the substance?
- Where and how do I need to pre-register?
- Registration
- Can a "category registration" be made, i.e. the consortium prepares a CSR for a category of substances (e.g. several compounds of the metal). The consortium members then use this single CSR which covers several compounds of the same metal to register their individual substances?
- Could a “consultant” or an “Association” take the role of Lead Registrant?
- Do I have to register as a trader?
- Do I have to register the substance or the use of the substance?
- Do substances that were already registered under the "existing substances" regulation have to be registered again?
- Do we have to provide information on the downstream use of materials that we sell but neither produce nor import?
- Do we have to register at the ECHA the substances that we import?
- Do “unintentional impurities” (from ores or secondary raw materials) have to be registered? What if they are CMR’s?
- Does registration have to take into account all tonnages placed on the market today?
- For companies with several different legal entities, will they be charged for registering each substance in each entity?
- For the M/I, does pre-registration automatically mean registration? Does this mean that registration bears on the pre-registered substances, or is it possible to register as UVCB a “sum” of the pre-registered substances (which have EINECS)?
- If a substance, metal or metal compound, has already been registered at the Agency by someone else, do you still have to register it?
- If I produce substances abroad, can I expect my customer to register these substances for the EU? Example: we use 31 metals or metal compounds. How can we check?
- If you produce in “tolling” conditions, who should then register, the owner or the operator?
- Is mechanical equipment (e.g. engines) up for registration?
- Is the EU REACH System (registration) also of relevance for OECD countries?
- Is the registration number linked to the substance, to the company, or both?
- No data, no market: does this mean that we have to register all substances that we can conceive of importing/manufacturing in the future? What happens if we start working with a new “material” that is phased-in and registered by somebody else after the time limits of registration have passed? We may import a substance after the end of pre-registration. Can we pre-register in anticipation of this to take advantage of phase-in timing?
- What happens in the case of a mixture of existing substances that are registered? Must the mixture also be registered? (mixture: no chemical reaction)
- Will Switzerland, Iceland, Lichtenstein and Norway be considered as part of the EU for registration purposes?
- Will the Agency accept registrations from a non-EU entity that exports into the EU?
