European Chemicals Association (ECHA) once published a report about under which kind of conditions chemicals can be registered as intermediates, also when distributors should submit the completed dossiers. (Registration of intermediate needs less dossier than chemicals). This report represented the comments of ECHA,EU committee and members of EU.
The contents of the report are based on the views of ECHA, REACH and CARACAL in charge of the CLP legislation. The industry circle commentted according to these views, and the report is also including those comments made by them. However, “This explain comes from EU committee and ECHA, but Industry circus does not agree with that” says Erwins Annys the authorized expert of ECHA and instructor of REACH..
Meanwhile, Erwins also supplement that some catalyst and chemical reactants used in production reveal two problems. If the catalyst or reactants could be regarded as intermediate while registration is submitted, it depends on exact conditions.
Furthermore, ECAH has already re-clarify the definition of intermediate,“Intermediate is under the purpose of manufacturing chemicals, not every reactants could be defined as Intermediate, the critical point is react into another reactants itself.
This report will be published in the latest amendment of “Direction of Intermediate”. but it will not revised until 30th Nov 2010. We will see a more completed REACH after clarified the different interpretation of intermediate formally.
By Ben |