EXEMPT MATERIALS
Exempt materials are described in the REACH legal text in Article 2 and includes pharmaceuticals and food additive. Note that crop protection products and biocides are not exempt, but are considered ‘registered’ under their own parallel systems. Substances that are used in exempt applications, but are used in other areas, will need registration under REACH; eg food grade colourants used in inks.
Specific exempt substances, including elements and natural products are described in Annex IV and V of the REACH legal text. These may change in time as more types and classes of materials are considered and the for updates, the ECHA web-site needs to be checked.
Manufacturers or importers who have Notified new substances under NONS will not need to register these as long as the Notification was in their name and registration numbers can be claimed. The old Notification dossiers in SNIF format can be re-formatted to IUCLID 5.
Cosmetics, food contact materials, medical devices and other specific types of chemical that are covered under their own Directives will need registration, but such materials may be exempt from certain parts of REACH, such as end-use risk assessment.
Waste is exempt from registration if it meets the criteria of the Waste Directive, but if sold for recovery, may not be exempt. This needs case-by-case consideration, but recovery from designated waste does not need registration if the substance is already registered in Europe.
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