My company is interested in joining the Lead REACH Consortium. How can we obtain information on the application process and the costs involved?
As a Consortium member, how can I find out more about the Consortium’s current work?
The biannual General Assembly meetings provide an ideal opportunity to find out more about recent developments in REACH, and to receive information on the progress under the Consortium’s extensive work plan. They are also a great forum to network with fellow Consortium members, and offer the opportunity to discuss with the Secretariat any specific regulatory matters affecting your company.
You can also keep up to date through our REACH Newsletter, which you can find in the Members’ section, together with a copy of this year’s Consortium work plan.
Which substances are managed by the Consortium?
The Secretariat developed, and continues to manage, the Lead Registration dossiers and Chemical Safety Reports, with all 26 substances being registered ahead of the 2010 deadline. The Consortium is actively engaged in the continuous improvement of those registrations, as well as wider regulatory activities and advocacy, particularly in the context of REACH Authorisation and Restriction.
Find out more about the work of the Consortium here.
As a new importer of lead substances needing to register for REACH, must I buy a Letter or Access or am I eligible to join the Consortium?
Consortium membership is open to companies involved in the mining, smelting, refining and recycling of lead, as well as manufacturers and importers of lead compounds and producers of lead-based automotive and industrial batteries. The LOA is offered as a convenient way of accessing the Consortium’s data for the purposes of REACH registration without becoming a member, and is often a cost-effective approach for legal entities in lower tonnage bands. However, Consortium membership provides many additional benefits.
Where can I find the latest classifications for lead substances?
The 9th ATP's harmonised classification for lead metal in massive form does not include a specific concentration limit. What does that mean for alloys containing lead metal?
In the absence of a specific concentration limit, the generic concentration limit applies which, for reproductive toxicity, is 0.3%. For STOT RE 1, the GCL is 10%.
Find out more about the impact of the harmonised classification for lead metal in the Consortium’s FAQ document, Lead Metal and the 9th ATP to CLP Frequently Asked Questions.
My legal entity needs to register a lead compound which is not under the Consortium’s remit. How do we obtain access to the Consortium’s data to use in a read-across approach?
How can my company use Lead REACH Consortium data for compliance with K-REACH and other non-EU legislation?
The Consortium encourages the lawful use of its datasets for compliance with other REACH-like legislation around the world, such as K-REACH. On payment of any relevant fees, non-member companies and non-EU consortia with such legal obligations may be granted a licence to use the Lead REACH Consortium’s data for use outside the EU.
Template Licence to Use (LTU) agreements are available to cover three situations:
- to extend the rights of Lead REACH Consortium Member companies to allow the use of the datasets in non-EU jurisdictions;
- to grant an individual non-member company the right to use a Lead REACH Consortium dataset for non-EU legislation;
- to grant a non-EU consortium, or a group of non-member companies, the right to use a Lead REACH Consortium dataset for non-EU legislation.
The template agreements set out the costs; the Consortium’s website provides more information on applying for a Licence to Use.
Please contact the Secretariat to discuss your particular situation in more detail.
Is the use of lead metal subject to REACH Authorisation?
Currently, no. Following a proposal by the Swedish Chemicals Agency (KemI), lead metal was included in the Candidate List of Substances of Very High Concern (SVHC) for Authorisation on 27 June 2018. Now that Pb metal is Candidate Listed, the European Chemicals Agency could recommend lead metal for inclusion in REACH Annex XIV as early as mid-2020. If Member States and the European Commission then agree, REACH Annex XIV would be amended; a transitional period would then apply before the use of lead metal in the EU on its own or in mixtures (subject to certain concentration thresholds) required Authorisation. The transition period could reasonably be in the region of 2-5 years.
The Lead REACH Consortium has published an updated set of Frequently Asked Questions on the Candidate Listing of lead metal, its impacts, and subsequent steps towards Authorisation.
Questions 6 to 8 in the Consortium’s Q&A document on classification, concentration limits, thresholds and communication obligations also provides some discussion on the applicability of REACH Authorisation should Pb metal be added to Annex XIV.