REACH+ requirements
According to the Fertilizing Products Regulation (EU) 2019/1009, “Where an EU fertilising product contains a substance or mixture within the meaning of REACH, the safety of its constituent substances for the intended use should be established through registration pursuant to that Regulation”.
Where the actual quantities placed on the market are lower than 10 tonnes per company per year, the information requirements determined by REACH for the registration of substances in quantities of 10 to 100 tonnes should exceptionally apply as a condition for use in EU fertilising products (REACH+).
Where the actual quantities of substances in EU fertilising products regulated by this Regulation are higher than 100 tonnes, the additional information requirements laid down in REACH should apply directly by virtue of that Regulation. The application of the other provisions of RREACH should also remain unaffected.
All substances incorporated into the EU fertilising product, on their own or in a mixture, shall have been registered pursuant to REACH, with a dossier containing:
(a) the information provided for by Annexes VI, VII and VIII to Regulation (EC) No 1907/2006, and
(b) a Chemical Safety Report pursuant to Article 14 of Regulation (EC) No 1907/2006 covering the use as a fertilizing product,
unless explicitly covered by one of the registration obligation exemptions provided for by Annex IV to REACH or by points 6, 7, 8, or 9 of Annex V to that Regulation.
Several concerns have emerged about whether these provisions are feasible or whether they will simply prove to be insurmountable obstacles that will force companies to place fertilizing products on the market under National Rules where normal REACH requirements still apply.
The following negative impacts have been identified in the Position Paper issued by EBIC in 2023:
- The REACH registration cost could increase considerably the cost of the final fertilizing product.
- Increased administrative burden due to the number of REACH registrations to be assessed.
- Possible scenario of endangerment of substance supplies due to lack of profitability or unwillingness to share information.
In case you need further information about REACH+ and how this can affect your fertilizing product, please contact us at admin@kaeltia.com, we will be pleased to assist you.
