The EU REACH Regulation and the CDI
As you will be aware, the EU’s new Regulation on the Registration, Evaluation, Authorisation and Restriction of Chemicals (REACH) entered into force on 1st June 2007. It is designed, using the principle of ‘no data, no market’, to shift onto industry the responsibility for assessing any risks relating to the substances it places on the EU market.
Manufacturers and Importers
All manufacturers and importers of chemical substances in the EU, including metals and metal compounds, in quantities exceeding one tonne per year will be required to submit a registration dossier to the new European Chemicals Agency. The registration dossier will contain detailed information on the substance, including a full chemical safety assessment and proposals for classification and labelling.
Downstream users of cobalt and cobalt compounds do not have to register, however there are requirements relating to the provision of information on their uses. As part of the registration dossier, manufacturers and importers that submit chemical safety assessment(s) are also required to generate ‘Exposure Scenarios’ covering the uses of their substances. Information on exposure that is required to develop the Exposure Scenarios will need to be provided to the manufacturers by the downstream users. Downstream users involved in less common applications should ensure that their uses are included in the registration dossiers.
The Board of the Cobalt Development Institute (CDI) has established three REACH Consortia to implement REACH on behalf of the cobalt industry. The main purpose of the consortia is to prepare the registration dossiers for 31 cobalt substances identified by the consortia members. The three cobalt REACH Consortia cover cobalt metal (BLUE Consortium), 15 inorganic cobalt compounds (RED Consortium) and 15 cobalt carboxylates (GREEN Consortium).
A separate wholly-owned subsidiary of the CDI called CoRC (Cobalt REACH Consortium Ltd.) acts as The Secretariat to the Consortia. A separate website has been developed for the Cobalt REACH Consortia (http://www.cobaltreachconsortium.org/home
The Cobalt Consortia encourages wide membership and active participation in the consortia. Interested companies with a number of cobalt substances are invited to consider joining the consortia. Downstream users of cobalt and cobalt compounds are welcome to join the cobalt consortia as Associate members for the purposes of data sharing. An option for a Letter of Access is also being developed for companies (co-registrants) with one or two cobalt substances in the lower tonnage bands.
If you would like to know more about the requirements of REACH or the Cobalt REACH Consortia, please contact the Secretariat at:REACHinfo@thecdi.com
Ms Carol Pettit, REACH Manager
Cobalt REACH Consortium Ltd
the Cobalt Development Institute
167 High Street
Tel: +44 (0)1483 510473/578877