The substances in the anodic layer do not have to be (pre-)registered under REACH.

As you know, we have put before the ECHA Helpdesk in Helsinki the question of whether an anodiser is to be considered a manufacturer of aluminiumoxide. We now got an answer our industry can be happy with. The Helpdesk's answer is based on a 'similarity with zinc coating' which of course does not hold. To be safe I therefore asked for a confirmation of ECHA's recommendation. But anyhow, we can now quite safely say that there is no need for pre-registration.

Pre-registration of materials such as aluminiumhydroxide is still recommended, unless the anodiser decides he is allways going to treat this substance as 'waste' which is out of the scope of REACH. If 'waste', then of course one has to make sure that the relevant waste legislation is followed, from transport to treatment. Pre-registration window ends December 1st 2008 !

Also pre-registration of substances that are not going to be pre-registered by suppliers should still be considered.

The next challenges of REACH for our industries, coaters and anodisers alike, are now

     - art 33 : check svhc-content in the coated products, and communicate to clients and consumers where necessary

     - as downstream users : anticipate operational problems where suppliers have not pre-registered their substances (on their own or in preparations),

     - make sure that the uses are identified (up to substance level) in the relevant Safety Data Sheets (participate in consortia ?)

     - prepare for enforcement by member states authorities (Seveso and IPPC-companies will probably be the first to be controled)

Simon Meirsschaut

Technical Coordinator