EUROFER REACH guidance for the European Steel Industry. 09.09 ...

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REACH Guidance for the European Steel Industry number for sinter, so pre-registration as MCS 11 is not necessary (for MCS you will have to mention all the constituent’s EINECS numbers). "Important Notice: This position paper is intended as a supplement to the REACH Regulation and the official REACH Technical Guidance Documents published by the European Chemicals Agency (ECHA). It is provided as an advisory document and, as such, has no legal standing. Therefore, in conjunction with this position paper, users are advised to consult Regulation EC 1907/2006 (for the legally binding requirements of REACH) and the official REACH Technical Guidance Documents (for detailed information on REACH implementation). It may also be appropriate to seek independent legal advice on matters related to pre-registration and registration. While every effort has been made to ensure the accuracy of this document, neither Eurofer nor the authors of this document accept liability for its content or for the use which might be made of the information herein." 11 Multiconstituent substance September 2009 30
REACH Guidance for the European Steel Industry EUROFER position paper 12 determining the borderline between preparations/articles for steel and steel products (28 October 2008) Background Regulation (EC) No 1907/2006 of the European Parliament and of the Council of 18 December 2006 concerning the Registration, Evaluation, Authorisation and Restriction of Chemicals (REACH), is a regulation on substances 13 . Unless exempted from scope or from registration in accordance with Annex IV or V, substances on their own or in preparations 14 are always subject to registration when manufactured in, or imported into, the EU. Substances on their own and in preparations in the form of , or contained in, articles produced in or imported into the EU are subject to registration only if they are intended to be released under normal or reasonably foreseeable conditions of use and if this use of the respective substance have not been registered before in the Community. This paper establishes the borderline between steel alloys (preparations) and steel products in the form of articles. In this paper, it will be shown that slabs, bars, billets and blooms made of steel alloys 15 have article status under REACH. The argumentation has been developed in close co-operation with the International Iron and Steel Institute (IISI) and is supported by the global steel industry in so far it applies to European law. Furthermore, this paper is based on a legal opinion received from the law firm “Mayer Brown International LLP”. Main Steel process stages There may be up to four main stages in steel processing. Overall, the first three stages are aimed to change and/or refine the shape and size of the material to progressively bring it closer and closer to its final main shape, as illustrated in the flow diagram on page 5 of this position paper. Stage 1: cast ingots In the first stage, liquid steel is poured into moulds having the shape and surface appropriate to the subsequent processing regardless of the chemical composition. The shape generally resembles a truncated pyramid or truncated cone, but cast ingots with additional shapes are also produced. Trade literature and standards 16 makes a distinction between cast slab ingots of rectangular cross section of width twice the thickness or over, and other cast ingots having a cross section that may be square, rectangular (of width twice the thickness), polygonal, round, oval or shaped according to the profile to be rolled. 12 Dated 29 August 2008 13 Definition of substance out of the REACH Regulation (Article 3 (1)) : means a chemical element and its compounds in the natural state or obtained by any manufacturing process, including any additive necessary to preserve its stability and any impurity deriving from the process used, but excluding any solvent which may be separated without affecting the stability of the substance or changing its composition 14 Definition of preparation more substances out of the REACH Regulation (Article 3 (2)) :means a mixture or solution composed of two or 15 Definition of alloy out of the REACH Regulation (Article 3 (41)) : means a metallic material, homogenous on a macroscopic scale, consisting of two or more elements so combined that they cannot be readily separated by mechanical means 16 EN 10079:1992 E, "Definition of steel products" September 2009 31
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Page 3 and 4: Preamble REACH Guidance for the Eur
Page 5 and 6: Relevant definitions out of the REA
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Page 10 and 11: Figure 1 - Flowchart outlining regi
Page 18 and 19: 3.1 Registration in the steel secto
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Page 54: 9 Annex VI: Case studies REACH Guid

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