Member States have alerted ECHA and the European Commission to industry positions on intermediates, which appear not to be in line with the definition of intermediates in REACH and the guidance on intermediates.
The purpose of the document agreed among all authorities is to explain to industry when a chemical substance can be solely registered as an intermediate and when a standard registration is required. The document underlines that an intermediate is a substance used in the manufacturing of another substance whereby the intermediate is itself transformed into that other substance.
It also clarifies that substances used in the production of articles cannot be regarded as intermediates.
The document contains a number of clear examples aimed at helping industry to determine whether their substances are intermediates. The definition is coherent with the approach taken on intermediates under the previous European chemicals legislation. The document was agreed between the European Commission, ECHA and the Member State Competent Authorities for REACH and CLP. It will be reflected in an update of the guidance on intermediates, which is in process and planned for publication after 30 November 2010.
The Commission, industry stakeholders and ECHA have in the context of the Directors' Contact Group identified practical solutions for companies facing difficulties for the first registration deadline, which include the situation of companies having still to register intermediates or that have already incorrectly registered substances as intermediates.
European Chemicals Agency
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