Questions & Answers

What is the REACH Regulation?

REACH is the Regulation (EC) No 1907/2006 of the European Parliament and of the Council on the Registration, Evaluation, Authorisation and Restriction of Chemicals. It entered into force on June 1, 2007.

The aim of REACH is to improve the protection of human health and the environment from the risks that can be posed by chemicals, while enhancing the competitiveness of the EU chemicals industry. It also promotes alternative methods for the hazard assessment of substances in order to reduce the number of tests on animals.

This Regulation establishes a series of obligations for all manufacturers and importers of chemical substances into the EU. All these companies need to register their substances jointly, in cooperation with other companies who are registering the same substance, according to the principle “One Substance, One Registration”.

The European Chemicals Agency (ECHA) receives and evaluates the registrations for compliance and may request additional information. Member States and ECHA’s scientific committees assess whether the risks of substances can be managed.
Registrants have the legal duty to keep their registration dossiers up-to-date with the most recent information on hazards and risks.

Who must register substances according to EU REACH?

All manufacturers within the EU or importers of chemical substances into the EU in quantities of 1 tonne or more per year are obliged to register their substances according to REACH.

Only a natural or legal person established within the European Economic Area (EEA)/EU can be a registrant. Companies not established in the EU do not have direct obligations under REACH, but they can appoint an Only Representative according to Article 8 of REACH.

A substance must be registered before the manufacture or import can start at an annual quantity of one tonne or more. Before the registration, the manufacturer or importer has to make an inquiry to ECHA regarding any previous registration for the same substance. Upon registration, the registrant may have to wait for three weeks after the registration dossier is submitted before starting or continuing the manufacture or import of the substance (Article 21 of the REACH Regulation).

How are complex inorganic pigments identified?

Complex inorganic pigments are chemical substances manufactured via high-temperature calcination of a mixture of raw materials (typically consisting of metal oxides and salts). As a consequence of this process, the raw materials are transformed into a new substance (the pigment), in which metals and oxygen atoms occupy specific places within the crystalline lattice.

For the identification of complex inorganic pigments, colour and crystal structure have been widely used as main parameters by industry. The Color Pigment Manufacturers Association (CPMA) maintains a list of inorganic pigments grouped into 14 crystalline structures with different contributing elements and colours. Colour Index International is a reference database listing thousands of dyes and pigments either organic or inorganic describing a commercial product by usage, its hue and a serial number.

For the identification and naming of complex inorganic pigments according to REACH Regulation, Eurocolour and IP Consortium agreed with ECHA to identify them according to their composition and crystalline structure, including all main contributing elements and the crystal structure in the EC name. For additional information, please refer to the Eurocolour Guidance Document.

Are metal oxides present as such in the complex inorganic pigments?

No. During the manufacturing process of complex inorganic pigments, a mixture of raw materials (typically consisting of metal oxides and salts) undergoes a calcination reaction at high temperatures. The chemical bonds of the raw materials are broken, and the atoms are homogeneously and ionically interdiffused to form a specific crystalline matrix. The raw materials are transformed into a new substance (the pigment), in which metals and oxygen atoms occupy specific places within the crystalline lattice.

The chemical reaction that leads to the manufacture of complex inorganic pigments involves the transformation of the raw materials, which are completely consumed in the process, into the new substance. In conclusion, there are no metal oxides present in the complex inorganic pigments.

Are inorganic pigments hazardous?

Because of the strong chemical bonds in the crystalline structure of the pigments, most complex inorganic pigments are not hazardous for human health or the environment.

Nevertheless, Inorganic Pigments Consortium generated information to assess the hazards and risks of the substances registered under EU REACH and continues to do so in the framework of the continuous improvement of the Registration dossiers. Each pigment is assessed against the classification criteria of EU CLP Regulation and classified according to the best available science.

Please refer to the Classification and Labelling section for specific information on all substances registered by IP consortium.

How to join the REACH Registration for complex inorganic pigments?

If you are interested in the REACH Registration of any of the substances covered by the Inorganic Pigments Consortium portfolio, you can purchase a Letter of Access.

The Letter of Access (LoA) is a short document that essentially grants recipients the limited right to refer to the joint registration dossier solely to register a specific substance under EU REACH.

With a Letter of Access:

  • You can refer to the registration dossier for REACH compliance within the EU (token + name of the Joint Submission)
  • You receive the necessary documents to complete your individual registration dossier.

Please contact us if you are interested in a Letter of Access for any of the IP Consortium substances.