Although those used to the REACH Registration process will be familiar with the use of IUCLID software and the procedures to follow, UK based companies who have been able to rely on DUINs or who need to import into the UK for the first time, or who are helping EU customers with EU REACH to allow export, may be facing the need for Registration for the first time.
Content
- Substance identity
- Spectral evaluation
- Chromatography
- Other analysis
- Nano-forms
- Methods of synthesis
- Outcome of analysis / Substance Identity
- Mono-consistent substances
- Multi-constituent substances
- UVCB - Unknown, Variable Chemical or of Biological origin
- Purity details / impurities
- Additives
- Other substance types
- ’Natural’ products
- Polymers
- Salts
- Justification
- Completing IUCLID
- Submission
- Outcome of the Inquiry
- Further guidance
With the exception of Production and Process Research and Development derogations, the first step for Registration needs to be an Inquiry. This step is needed to establish the identity of the substance and to determine if other Registrations are held. In the case of GB REACH, this only currently links to Registered substances (Grandfathered or new submission) and there is no link to substances declared as DUINs.
In terms of software skills, completing the IUCLID takes only a couple of hours for an Inquiry (although for new users, mastering IUCLID will take longer), but the difficult part is ensuring that the analytical data presented is sufficient to confirm the substance identity and purity.
One area of IUCLID that can lead to problems is the way in which components are reported in Section 1.2. The way this is completed is dependent on the type of substance being Registered.
The process is not difficult once the software is mastered and if some simple rules are followed.