Substances not registered for REACH
Many substances are made or imported into the UK which do not hold a REACH registration at the time of writing (November 2017), and which are produced in such small quantities that they will never go through REACH registration.
In this situation, there will not be REACH registration data available to support a CLP classification for that substance, and only limited published information which does not include much data.
Note that when a substance isn’t registered for REACH, you can’t simply can ignore it’s CLP classification (e.g. in a mixture classification), or assume that it hasn’t got any hazards. It may still be hazardous, and you still need to classify it for CLP, and use that information for the substance itself, or in a mixture, for labelling and the SDS purposes.
Your classification options include:
- using a classification from the C & L inventory
- using a classification from a reputable supplier’s SDS (but make sure this has also been notified to the C & L inventory)
- read-across to similar substances (expert toxicological/ chemical help may be needed)
- having tests carried out to find out what the classification might be – these can be physico-chemical, or tests supporting the classification.
Whichever classification method you choose, you should keep all of your reasons and workings on file, in case new information comes to light which means the classification needs to be altered.
Also, just because a substance isn’t registered for REACH doesn’t mean you don’t need to carry out tests. Under CLP, classification is supposed to be on the basis of test data, with other methods being less reliable, so in theory you could be asked to do this (e.g. by the Competent Authority), although in practical terms, many small-volume chemicals are unlikely to generate enough profit to pay for these tests.
The SDS for a substance which has not been registered for REACH is not required to have specific data (matching the REACH registration), but you should still do your best to include all relevant test data in sections 9, Physical and chemical properties; 10, Stability and reactivity; 11, Toxicological information; and 12, Ecological information.