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REACH Update: Specifics for Naturals
Posted: April 8, 2008
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The REACH approach for natural polymers is still open for decision by the EU-Commission. Questions include: Are they exempt as polymers? And in relation, what monomers are to be registered? Or, are natural polymers only exempt when listed in Annex IV? The actual entries in Annex IV are also under review for inclusion or deletion. Consequently, the reviewed annexes have to be studied before pre-registration.
Other classes of natural substances are exempt from the provisions of REACH, according to Annex V(8). These include minerals and ores,such as mica, if they are not chemically modified.
Annelie Struessmann, PhD
*Readers are reminded that the text of the REACH Regulation (EC) No 1907/2006 is the only authentic legal reference. The information in this column does not constitute legal advice.
• Substances occurring in nature are exempt from registration, evaluation and downstream user obligations
• This includes naturals only if they have not been chemically modified or classified as dangerous
• The solvent allowed for processing of naturals is exclusively water
• In flotation processes, addition of detergents is possible
• Plant extracts from nonaqueous extraction solvents fall under REACH
• Proteins are naturals when they are not chemically-modified during extraction or purification
• Protein hydrolysates, amino acids and biotechnology-derived products are developed from modifications of initial substrates and thus fall under REACH.
• Minerals are exempt from REACH if they are not chemically modified