REACH

 

 Glass under the REACH Regulation

The REACH Regulation, Regulation EC N° 1907/2006 on the Registration, Evaluation, Authorization and Restriction of Chemicals, is the European Union's regulatory framework on chemicals and their safe use. It entered into force on 1st June 2007. It streamlines and improves the former legislative framework on chemicals of the European Union.

 REACH makes the industry responsible for assessing and managing the risks posed by chemicals and for providing appropriate safety information to their users. In parallel, the European Union can take additional measures on highly dangerous substances, where there is a need for complementary action at EU level.

 Glass Alliance Europe has written a specific document to describe the REACH Regulation and the application to the glass industry (link to Guidelines for the glass industry "Registration, Evaluation, Authorization and Restriction of Chemicals, REACH")

Nature of Glass

Glass is an inorganic material obtained from different inorganic raw materials which react at high temperature to form a new random network, where different elements are linked together, typically by oxygen bridges. Under the REACH Regulation glass is considered as a UVCB substance (substance of unknown or variable composition, complex reaction products or biological materials).

The general chemical formation for silicate glass can be illustrated by the following simplified reaction equation:

a SiO2 [sand] + b Na2CO3 [soda] + c CaCO3 [lime] + d CaMg(CO3)2 [dolomite] + e Na2SO4 [sodium sulphate] +….. → x SimNanCaoMgp……Os) [glass] + y CO2 ↑+ z SO2 ↑ + …..

Raw materials used in a glass formulation undergo physical (melting) and chemical (formation of the network) processes. During the chemical reaction to form glass (synthesis), different crystalline substances (a, b, c, d, e, …) are transformed into a non-crystalline vitreous substance (x).

The physico-chemical properties of the new substance glass (chemical resistance, mechanical resistance, transmittance, colour, etc.) are a function of the network formed. Different compositions lead to different glass chemical structures and consequently to different physico-chemical properties of the final material.

Glass Description and Raw Materials Used to Produce Glass

Glass is a substance of variable composition, which by convention is expressed as oxides of the constituent elements (SiO2, Na2O, K2O, PbO, etc.). Although conventionally glass compositions are expressed as oxides of the different elements, glass is not a mixture of the different oxides or raw materials, but a substance which does not contain these oxides as such. Glass can better be identified by its chemical formula SimNanCaoMgp……Os [glass].

Raw materials used to manufacture the substance glass are transported isolated intermediates which are completely consumed and transformed into the new substance glass during the manufacturing process.

Glass and Registration : Exemption of the Substance Glass

Based on the nature of the substance glass and its specific generic inertness, the Commission added glass to the list of substances exempted from the "obligation to register" (Reach Regulation Annex V (11)). This exemption is limited to the compliance with the following requirements:

"The following substances unless they meet the criteria for classification as dangerous according to Directive 67/548/EEC and provided that they do not contain constituents meeting the criteria as dangerous in accordance with Directive 67/548/EC present in concentrations above the lowest of the applicable concentration limits set out in Directive 1999/45/EC or concentration limit set out in Annex 1 to Directive 67/548/EEC, unless conclusive scientific experimental data show that these constituents are not available throughout the life-cycle of the substance and those data have been ascertained to be adequate and reliable : Glass, ceramic frits". (*)

The European Glass Industries, with the contribution of three independent experts, defined a guideline enabling glass manufacturers to check if their glass is exempted according to the previous requirements. Considering the intrinsic inertness of glass, the majority of glass types fulfill the criteria laid down in Annex V (item 11).

It is the producer's responsibility to assess the substance glass and to demonstrate with conclusive scientific data that this substance fulfils the criteria.

Glass Alliance Europe publications and contributions concerning REACH

Glass Alliance Europe issues documents and position papers and participates actively in consultation processes carried out by ECHA (European Chemicals Agency) involving glass and the raw materials used to produce glass.

Below are the links to the main documents and position papers developed by Glass Alliance Europe:

(*) The EU Directives on classification, labelling and packaging of substances (Directive 67/548/EEC) and preparations (Directive 1999/45/EC) referred to in this REACH Dossier have now been replaced by the EU Regulation 1272/2008/EC (called “CLP Regulation”).

Glass and ECHA Website

On 5 March 2012 ECHA published on its website a list called “Data on Candidate List substances in articles” providing examples of articles containing SVHCs that are on the Candidate List and that are available for consumer use on the EU market. Multiple referrals are made to glass articles on this list  stating that the articles contain SVHCs. This leads to misunderstanding and confusion for consumers as well as our customers. The information on the ECHA website implies that some SVHCs remain present in those glass articles. To our knowledge this is not the case, and consequently there is neither need nor justification for the notification required by ECHA. Thus GAE asked ECHA to remove this information and data referring to glass articles on the above mentioned website to make it clear that "glass articles that consist entirely of the substance glass do not contain SVHC". ECHA agreed to make our point clearer in the explanatory text with the next update of the website. See link to ECHA's reply.

Frequently Asked Questions on Glass under REACH