REACH Substance Identity
May 15th, 2018
The final REACH deadline has passed, but substance identity is still important.
- Included more than one hazard profile under a single Registration?
- Registered an organic salt?
- Ignored impurities?
- Registered a UVCB and/or naturally-derived substance?
- Presented limited evidence for your composition and sameness within the SIEF?
If you answer yes to any of these then you may be hearing from ECHA about your substance identity. It is PFA’s experience that many Registrants have underestimated the requirements in this area. Substance identity is fundamental to the chemical safety assessment and very much on ECHA’s mind. If you have concerns, it may be worthwhile considering a pre-emptive Dossier update to avoid ECHA imposing an undesirable solution.
PFA scientists have a huge amount of experience in substance identity for REACH and other regulations. Recent successes include defining complex naturally-derived UVCB substances, and having some complex substances accepted as multi-constituent rather than UVCB.
We find that having a narrative around the analytical data is important even for a straightforward substance, but for a complex one it is essential. We can help you with this and all aspects of the substance identity from designing an analytical test programme to completing the boundary composition in IUCLID6.
Please contact us for a discussion of your needs.