REACH Implementation by Concawe and its Member Companies

Building on its Risk Assessment Programme (see web page on Petroleum Products), Concawe had a programme in place under which it developed for its members not only those parts of REACH Registration Dossiers for which agreement amongst registrants is obligatory and which have to be submitted to the ECHA by a Lead Registrant, but also all other parts of the Registration Dossier which can be submitted jointly on a voluntary basis.

Petroleum substances (except sulfur and a few mono-constituent petroleum gases) are recognised by REACH as substances of “Unknown or Variable composition, Complex reaction products or Biological materials” (“UVCBs”). UVCBs are notoriously difficult to assess for their intrinsic properties and, where applicable, risks. Under its comprehensive Risk Assessment Programme on Petroleum Substances, Concawe developed methodologies that allow such assessments.

Note: The Concawe Risk Assessment Programme covers most, but not all petroleum substances listed in the Official Journal of the European Commission OJ L 84 of 5 April 1993. It does not, for example, cover steamcracker products, hydrocarbon solvents, lubricating greases, and re-refined base oils. It also does not cover substances which are exempt from Registration under Annex V of REACH, for example crude oil or petroleum coke.

There are other REACH related issues which are of particular relevance or unique for petroleum substances, for example:

  • Who in the supply chain is the importer under REACH and is therefore obliged to register an imported substance?
  • Which processes can be regarded as manufacturing of substances under REACH and therefore oblige the operator to register the manufactured substance(s)? Which processes constitute making a preparation?
  • How can imported petroleum substances be identified in terms of CAS Registry or EC number? How to avoid situations in which importers can no longer import a substance only because they have registered it under a different CAS/EC number?