Registration of ferro-alloys
Key references in REACH:
- Any manufacturer and importer of a substance on its own or in a preparation in quantities of 1 tonne or more per year shall submit a registration to the Agency (Art. 6).
- All metals are substances and phase in substances as defined in the regulation (Art. 3-1 & 3-20).
- Preparations are defined as mixtures or solutions of two or more substances (Art. 3-2).
- Alloy: means a metallic material, homogenous on a macroscopic scale, consisting of two or more elements so combined that they cannot be readily separated by mechanical means (Art. 3-41).
- Metallic alloys are referred to as special preparations in Recital 31 of the Regulation that recommends the development of a special methodology for their assessment (Recital 31).
- When assessing the risk of the use of one or more substances incorporated into a special preparation (alloys, for instance), the way in which the constituent substances are bonded in the chemical matrix must be taken into account (Annex I - 0.11)
All smelted alloys are subject to registration requirements
Options for ferro-alloys:
There are 2 options for registering (and pre-registering) ferro-alloys:
- as “substances in preparations”, which is the strict application of Art. 6 = standard route
- as multi-constituent substances (MCS)