Implications of REACH for. Industrial Minerals. SSDCEI 12 December 2007

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1 Implications of REACH for Industrial Minerals 1

2 Minerals under REACH OUTLINE Status of Industrial Minerals Minerals & Registration Minerals & Evaluation Classification & labelling inventory Review of REACH Regulation 2

3 Status of minerals under REACH (1) An industrial mineral is a substance on its own A milk of lime or a slurry are preparations, i.e. containing two or more substances Aggregates are usually articles containing substance(s) Plaster board is an article containing substances 3

4 Status of minerals under REACH (2) 1) Registration & Evaluation The following minerals are exempted because they clearly fulfil the exemption granted in Annex V, point 7 Mineral and ores which occur in nature, if not chemically modified : Cristobalite (natural), Bentonite, Calcium carbonate (natural), Chlorite, Colemanite, Diatomite, Dolomite, Feldspar, Gypsum (natural), Hydroboracite, Kaolin, Kaolinitic clays, kernite, Limestone, Plastorite, Quartz, Sepiolite, Talc, Tincal, Ulexite, Vermiculite, Wollastonite,... 4

5 Status of Minerals under REACH (3) The status of the following minerals is unclear regarding Registration & Evaluation: Precipitated calcium carbonate, FGD Gypsum, Sodium-flux calcined diatomite, In the current version of the REACH Regulation, the following substances are subject to Registration & Evaluation: Boric acid, Boron oxide, Disodium octaborate tetrahydrate, Disodium tetraborate, anhydrous Calcium oxide, Calcium dihydroxide, Calcium-magnesium oxide, Calcium-magnesium tetrahydroxide 5

6 Status of minerals under REACH (4) 2) Information into the Supply Chain This provision applies to all minerals 3) Notification to the Classification & Labelling Inventory This provision applies to all minerals meeting the criteria for classification as dangerous substances 4) Authorisations This provision applies to all minerals considered as substances of very high concerns (CMR categories 1 & 2, PBT, vpvb, or equivalent) CMR: Carcinogen, Mutagen, toxic to Reproduction PBT: Persistant Bioaccumulative and Toxic vpvb: very Persistant very Bioaccumulative 6

7 Minerals & Evaluation Registration Evaluation deadlines (if Pre-Registered) substances 1000 tonnes 1 December CMR (categories 1 or 2) substances 1 tonne substances very toxic to aquatic organisms 100 tonnes 1 June substances 100 tonnes 1 June substances 1 tonne CMR: Carcinogen, Mutagen, toxic to Reproduction PBT: Persistant Bioaccumulative and Toxic vpvb: very Persistant very Bioaccumulative 7

8 Classification & labelling inventory REACH Title XI (to be repealed by GHS) Manufacturers and importers of substances must notify their C&L to Chemical Agency by 1 December 2010 latest. This includes dangerous substances even if they are not subject to registration (e.g. minerals) Agency must record different C&L In case of phase-in (=existing) substances, participation in SIEF June December 2008 will trigger obligation to agree on common C&L MS may request harmonized classification and start evaluating substances if different C&Ls recorded E.g. Lime: Irritant Xi, R38, R37,R41 8

9 REACH Timeline (3) Ongoing Review of the REACH Regulation ANNEX I General provisions for assessing substances and preparing chemical safety reports ANNEX IV Exemptions from Registration & Evaluation as sufficient information is known about these substances that they are considered to cause minimum risk because of their intrinsic properties; ANNEX V IMA-Europe s position: Exemptions from Registration & Evaluation as registration is deemed inappropriate or unnecessary for these substances and their exemption from these Titles does Ensure that the exemption granted to not prejudice the objectives of this Regulation minerals will neither be deleted nor altered 1 June 2008 Clarify unclear situations 9

10 On-line The IMA REACH Hub User-friendly Documents database General REACH-related information Specific information for REACH implementation in the IM sector 10

11 The IMA REACH Hub Includes Guidance for assessing role & obligations (substance & preparation) Guidance for assessing role & obligations (article) coming soon Excel sheet for establishing substances inventory Letters for Downstream users Excel sheet for information requirement for registration Form for collecting information on legal entities ID cards Revised SDSs REACH compliant version Information Workshops 11

12 Status of minerals under REACH (2) A coated mineral (1) is a preparation compliant with REACH, if the 3 following conditions are met: the mineral used as the substrate substance, is a substance marketed in compliance with the REACH Regulation; the coating agent is a substance marketed in compliance with the REACH Regulation; the modification takes place solely on the surface of the substrate substance (1) A coated mineral is a surface-modified mineral which results from a treatment with a coating agent solely intended to give a specific physicochemical characteristic. The coating process only occurs on the surface of the mineral used as the substrate substance. 12

13 Minerals & Registration (2) IMA-Europe adopted the position that calcined minerals such as calcined kaolin are exempted because they fulfil the exemption granted in Annex V, point 7 Mineral and ores which occur in nature, if not chemically modified A mineral which has undergone a calcination process is considered as a not chemically modified substance, if any of the following cases below, alone or in combination apply: the calcination process results in the removal of impurities, the calcination process results in the removal of water (i.e. free and structural water), the calcination process results in a physical mineralogical transformation the calcination process leaves the chemical composition (with the exception of water and impurities) unaffected, 13

14 Conclusions 1. The mineral sector is impacted by REACH 2. Few registration foreseen, but costly where required 3. Customers expectations for Environment, Health & Safety information will grow 4. Main obligations for minerals as Downstream users of substances 1. The review of the Annex V 2. Deletion of the exemption by 2019 Threats 14

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