In what cases is REACH Registration not needed?
- For substances (either on their own, in mixtures or in articles) manufactured or imported in volumes below 1 tonne per year. In this case you should remember, that there are several obligations under REACH. Registration requirements only apply to substances that are manufactured or imported in quantities of 1 tonne or more per year per registrant. However if a substance is manufactured/imported at less than 1 tonne per year per registrant, other obligations under REACH may still apply if the substance falls within the scope of REACH. These obligations, which may apply irrespectively of the volume, include obligations concerning use of the substance, restrictions, authorisation and communication in the supply chain, such as the provision of safety data sheets. According to Articles 31 and 32 of the REACH Regulation some changes in the Safety Data Sheet (SDS) are required. Guidance for the compilation of Safety Data Sheets is given in Annex II of the REACH Regulation. ECHA has published several guidances on this question too (see question 20 in our FAQs on REACH).
- For substances, that are exempted from registration or regarded as being already registered, according to provisions in Articles 2, 9, 15 or 24 of the REACH Regulation.
Pay attention, that Commission Regulation No 987/2008 of 8 October 2008 amended REACH as regards Annexes IV and V.
According to amended Annex V the following substances are exempted from the obligation to register:
The following substances which occur in nature, if they are not chemically modified:
Minerals, ores, ore concentrates, raw and processed natural gas, crude oil, coal.
Substances which occur in nature other than those listed above, if they are not chemically modified,
unless they meet the criteria for classification as dangerous according to Directive 67/548/EEC or unless they are persistent, bioaccumulative and toxic or very persistent and very bioaccumulative in accordance with the criteria set out in Annex XIII or unless they were identified in accordance with Article 59(1) at least two years previously as substances giving rise to an equivalent level of concern as set out in Article 57(f).
The following substances obtained from natural sources, if they are not chemically modified, unless they meet the criteria for classification as dangerous according to Directive 67/548/EEC with the exception of those only classified as flammable [R10], as a skin irritant [R38] or as an eye irritant [R36] or unless they are persistent, bioaccumulative and toxic or very persistent and very bioaccumulative in accordance with the criteria set out in Annex XIII or unless they were identified in accordance with Article 59(1) at least two years previously as substances giving rise to an equivalent level of concern as set out in Article 57(f):
Vegetable fats, vegetable oils, vegetable waxes; animal fats, animal oils, animal waxes; fatty acids from C6 to C24 and their potassium, sodium, calcium and magnesium salts; glycerol.
The following substances if they are not chemically modified:
Liquefied petroleum gas, natural gas condensate, process gases and components thereof, coke, cement clinker,
magnesia.
The following substances unless they meet the criteria for classification as dangerous according to Directive
67/548/EEC and provided that they do not contain constituents meeting the criteria as dangerous in accordance
with Directive 67/548/EEC present in concentrations above the lowest of the applicable concentration limits set out in Directive 1999/45/EC or concentration limits set out in Annex I to Directive 67/548/EEC, unless conclusive
scientific experimental data show that these constituents are not available throughout the lifecycle of the substance and those data have been ascertained to be adequate and reliable:
Glass, ceramic frits.
Compost and biogas.
Hydrogen and oxygen.