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Before REACH

How to manage risk before REACH implementation?

In France, from 2007 to 2017 which is the implementation period of REACH ("Registration, Evaluation and Authorization of Chemicals"), integration into the regulations can be done in two different ways for a compound occurring simultaneously in a "classic" form and in a "nano" form. Either we consider these two forms as a single substance (already on the market) or as two separate substances.

If the nanomaterial is regarded as a substance that has never been marketed

151-reglementation-NON

"Nano" form is considered as a new product.

If the nanomaterial is regarded as a substance that has never been marketed, its dangerousness must be assessed and communicated by the person responsible for placing it on the market to the competent authority of the State concerned (Directive 67/548/EEC and Labor Code R.231-52).

Simplified files for progressive thresholds (10 kg, 100 kg, 1 tons/year) and more complete files are planned for higher thresholds (10, 100, 1 000 tons/year and by manufacturer).