REACH: same substance
identity (RIP 3.10)
Dr. Erwin Annys
Sr. Advisor
Product & Innovation Policy
WERCS 2007 EU User group
Napoli 31/05/07
What is the same substance: two
steps
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What is my substances ?
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Identification: name, CAS number, EC number,
…
Description:
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Analytical data :
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Impurities
Production process, purification process, …
Spectra
Chromatograms
Is my substance the same as the
substance of another registrant ?
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Substance identification is important
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REACH is based on substances
There are changes from EINECS reporting
rules
For pre-registrations and registrations you
need to define your substances
Identification of same substances is important
for data sharing/consortium/SIEF formation,
grouping and for non-phase-in substance
registrations
Identification of the substance used to
generate (existing) data is important
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REACH definition of “substance”
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A chemical element and its compounds in the
natural state or obtained by any
manufacturing process
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Including
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Any additive necessary to preserve its stability
Any impurity deriving from the process used
Excluding
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Any solvent which may be separated without affecting the
stability of the substance or changing its composition
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REACH Definition of “Substance”
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The definition goes beyond the
“textbook definition” of a pure
compound defined by a single molecule
RIP 3.10 explains how to interpret the
definition
RIP 3.10 explains how to name and
describe substances for (pre-)
registration
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Identification for pre-registration
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Full substance identification NOT required
To be submitted:
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Name of the substance (IUPAC or other
international chemical name)
EC-number (if available & appropriate)
CAS name and CAS number (if available)
Substance identification to facilitate the
formation of SIEFs
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Identification for registration
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Registration
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Shall include information on the identification of the
substance
Shall be adequate to enable each substance to be
identified sufficiently
If not technically possible or scientifically
necessary to give information on a substance
parameter a scientific justification is needed
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Identification for registration
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Identification parameters listed in Annex VI:
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IUPAC and/or other names, EC-number, CAS name/
number, other identifiers
Molecular and structural information (e.g. formulae,
MW, SMILES code, optical activity….)
Chemical composition (constituents, impurities,
additives for stabilization)
Supporting analytical data (IR,UV, NMR, MS, HPLC,
GC etc., as appropriate)
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Constituents
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Individual chemical species (molecules)
in a substance are called constituents
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A substance consists of “constituents”
A preparation consists of “components” or
“ingredients”
Constituent ≠ component or ingredient
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Types of substance
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Well defined substances:
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Mono-constituent substances
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Multi-constituent substances
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One main constituent ≥80%
Two or more main constituents between 10 80%
In both cases ca.100% of the composition
can be defined
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Types of substance
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Poorly defined or variable substances:
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Also known as UVCB-substances of Unknown or
Variable composition, Complex reaction products or
Biological materials
Cannot be sufficiently identified by their
composition
 Number of constituents is relatively large
 Composition largely unknown, very variable or
poorly predictable
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Mono-constituent substances
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One constituent substance
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Main constituent > 80% (w/w)
Impurities < 10% (w/w)
∑ main constituent, impurities and additives
= 100%
Impurities > 1% and impurities relevant for
classification must be mentioned (name,
CAS nr,…)
Name: name of the main constituent
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Mono-constituent substances
Examples
Main Constituent
%
Impurity
%
Name
m-xylene
91
o-xylene
5
o-xylene
87
m-xylene
10 o-xylene
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m-xylene
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Mono-constituent substances
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Deviation from 80% rule is possible with
justification, if:
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The range of concentrations for the main
constituent and the impurities overlap the 80%
criterion and the main constituent is only
occasionally ≤ 80 %
The main constituent is < 80% but the substance
can be shown to have similar physico-chemical
properties and the same hazard profile as other
mono-constituent substances with the same
identity that fulfill the 80% rule
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Multi-constituent substances
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Multiple constituent substance
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Two or more constituents > 10% en < 80%
Impurities < 10%
∑ main constituents, impurities and
additives = 100%
Impurities > 1% and impurities relevant for
classification must be mentioned (name,
CAS nr,…)
Name: mixture of
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Multi-constituent substances
Example
Main
Constituents
%
Impurity
m-xylene
50 p-xylene
o-xylene
45
%
5
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Name
Mixture of:
m-xylene
and
o-xylene
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Well defined but more identifiers
needed
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Some substances need to be defined by more
than just their chemical composition
Same naming and identification rules as
mono- or multi-constituent substances
PLUS
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Other physical or characteristic parameters: e.g.
crystallomorphology, (geological) mineral
composition
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Examples: some crystalline inorganic minerals such as
aragonite (a specific form of CaCO3)
Additional analytical evidence required e.g. X-ray
diffraction, elemental analysis
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UVCB substances
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Any substance which is not a “well defined substance”
RIP 3.10 gives generic guidance on main parameters
to identify UVCB’s (additional to Annex VI part 2)
If the substance can be fully identified it is wise to
treat it as a well-defined substance, not a UVCB
A UVCB of the same composition but derived from a
different source and/or process is a different
substance, and will likely require a separate
registration
Specific detailed guidance for:
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Substances with variations in C-chain length
Substances obtained from oil and oil-like sources
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General guidance for UVCBs
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Main constituents and impurities not really distinguished
Chemical composition and identity of constituents should
be given as far as is known
Can describe in a more general way than for welldefined substances (e.g. linear fatty acids C8-C16)
Composition can be described in terms of indexes,
fingerprints, reference standards etc.
All known constituents present at >10% should be
specified by name, CAS number, typical concentration
and ranges
All constituents relevant for classification must be
identified
Unknown constituents identified by general chemical
description, where possible
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General guidance for UVCB’s
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Naming should be in the order of source and
then process
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Biological sources are identified by the name of the
species
Non-biological sources are identified by the starting
materials
Processes are identified by:
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Type of chemical reaction (e.g. alkylation, chlorination)
Refinement step (e.g. extraction, fractionation,
concentration)
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Types of UVCB substances
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Biological substances
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Process is synthesis
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Process is refinement
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Includes chemical or biochemical derivatives of plant
extracts
Includes extracts and concentrates of plant extracts
Chemical and mineral substances
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Process is synthesis
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Poorly defined chemical reaction products
Process is refinement
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Includes petroleum substances, purified minerals
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UVCB Example
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Chemical derivative of a plant extract:
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Fatty acids, coco, compounds with diethanolamine
EC 263-153-4
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CAS 61790-63-4
Condensation products of coco
fatty acids and diethanolamine
UVCB because
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Complex mixture of amides formed from various fatty
acids present in the coconut oil
Ratio of fatty acids can vary in the source
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UVCB Example
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A refined product of a plant-derived
substance:
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Turpentine oil
EC: 232-350-7 CAS: 8006-64-2
Any of the volatile predominately
terpenic fractions or distillates
resulting from the solvent extraction
of; gum collection from, or pulping of
softwoods. Composed primarily of
the C10H16 terpene hydrocarbons:
alpha-pinene, beta-pinene, limonene,
3-carene, camphene. May contain
other acyclic, monocyclic or bicyclic
terpenenes, oxygenated terpenes
and anethole. Exact composition
varies with refining methods and the
age, location and species of the
WERCS EU Usersoftwood
group 2007 source
–
Erwin Annys
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UVCB Example
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A chemical derivative of a chemical
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Reaction product of a di-carboxylic acid and
amino-alcohol
EC 294-006-2
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CAS: 91672-02-5
Reaction products of
nonanedioicacid and 2-amino2-methyl-1-propanol
UVCB because
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Complicated mixture of amides and esters
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Checking if substances are the same
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Needs expert judgement
Equivalent substances should contain
the same main constituents:
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Apply ≥ 80% (mono-const.) and 10 – 80 %
(multi-const.) rules
No differentation between “pure”,
“technical”, “analytical” grades
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Checking if substances are the same
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If substances are “similar enough” then data
sharing is possible
However, if impurity profile differs markedly
then data sharing (or even presence in same
SIEF) may not be appropriate
Data sharing may also be possible with similar
(but not “the same”) substances by grouping,
category approach, read-across (see RIPs 3.3
and 3.4)
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Same/different substances: examples
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Hydrates and water-free substances
considered the same
Chiral centres are mixture of racemates (in
absence of proof of the contrary)
Acids or bases and their salts are different
Salts of different cations (Na, K, Ca, etc.) are
different
Branched vs linear, saturated vs unsaturated
are different
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Remaining issues
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RIP 3.10 has not addressed all cases
“Reaction products” issue:
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UVCB’s:
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Mixed reaction products must be registered as
substance (multi-constituent or UVCB)
Cannot register individual constituents
Different sources may mean different substances,
even if composition is very similar
RIP 3.10 appears to demand “complete”
similarity to be the “same substance
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