Page 48 - CITDBooklet

Guide on the application of REACH Regulation

Apart from this persistence [PBT’s- as pigments are insoluble in water and may persist
in environment for extended periods] and Volatile Organic components are of great
concern.

8.5 Polymer Industry

Polymers are exempted from certain obligations under REACH. However monomers
are not.
For polymer manufacturers it is very vital to first establish that their substances meet the
definition of polymers. Thus molecular weight distribution data is of utmost importance.
Monomers need to be registered. As long as one is using /importing monomers that have
been manufactured in EU, there is not much of a problem as the Up-stream manufacturer
of monomers would have done the registration. However if the monomers are procured
from other countries (Saudi Arabia or Japan etc.) then these need to be registered by
manufacturer or importer of polymers.
Data on residual monomers such as Acrylamide is important as it is an SVHC. Similarly catalysts
used in polymerization process need to be screened.
Surfactants based on APEO’s (alkylphenol ethoxylates) should be avoided.

8.6 Perfumery Industry

Ingredients of perfumes can be either synthetic or natural. Natural essential oils used in
perfume will be exempted from certain obligations under REACH, if these natural products
are not chemically modified.
Manufacturers / exporters must have data regarding name of the substance, source, species,
process used for extraction (not involving chemical modification) etc. to claim exemption.
Synthetic perfumes will have to be treated like any other chemical substance.
Sometimes certain Phthalates have been used as carriers of perfumes. These may be affected
by SVHC list.

8.7 Inorganic chemicals Industry

Inorganic chemical industry needs to carefully examine various inorganic compounds
included in the SVHC list. Toxic heavy metals are of great concern and thus both SVHC and
Annex XVII list needs to be constantly monitored

8.8 Natural products Industry

Natural products, if not chemically modified are exempted.
Annex IV list several products which can avail exemption such as:

■ Glucose
■ Ascorbic acid
■ Stearic acid
■ Mannitol
■ Sunflower oil
■ Soybean oil
■ Castor oil
■ Lecithin
■ Fatty acids

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