‘Reach’ Regulations: Impact on the European Fertiliser Industry

Keywords: REACH, compound fertiliser, substance identification, phase-in status, preparation, constituent, registration dossier, consortium.

The new European chemicals legislation ‘REACH’ (Registration, Evaluation, Authorisation and Restriction of Chemicals) requires chemicals produced within or imported into the EU to be registered. This obligation applies not only to new substances, but also to materials that have been on the market for many decades. For the majority of existing products, a phased implementation is possible.

Complying with REACH causes significant work and additional cost. For the registration dossiers, reliable core data including physical and chemical properties, as well as effects on human health and the environment have to be collected, production technologies and uses have to be identified and exposure scenarios are needed for potentially dangerous materials.

Downstream users should ensure the availability of their raw materials, as manufacturers or importers might abandon products to avoid the cost of their registration.

The fertiliser industry faces an additional challenge. Fertilisers were excluded from the European Inventory of Existing Commercial chemical Substances (EINECS) listing under Directive 67/548/EEC, which has raised doubts about their phase-in status. Substance identification rules for complex mixtures under REACH are not consistent for different material classes and — at least for compound fertilisers — not consistent with the previous legislation. Hence, clarification is needed to ensure formally the option of phased implementation.

A REACH task force instituted by the European Fertilizer Manufacturers’ Association (EFMA) has developed a registration strategy for compound fertilisers. For joint submission of the core data, a consortium is formed by the European fertiliser manufacturers, which also offers advice to non-members.

Johan Ebenhöch, BASF SE, E – CAD/L – M505, D-67056 Ludwigshafen, Germany.

20 pages, 2 tables, 13 references.