The final text of the REACH regulation contains some important aspects for the metals industry. Within the process of authorisation it has been decided that substitution is not mandatory, but companies are obliged to develop a substitution plan. Substances that meet the criteria for “very high concern” will be liable to authorisation and get onto the so-called candidate list. The first list will be published in two years time, therefore authorisation is likely to span over a time frame of decades as the Agency will only be able to work on approximately 20 substances per year.

Ores and concentrates (as long as not chemically modified) have been excluded from registration. There is still a theoretical but rather unlikely risk that ores and concentrates will be prioritized for authorisation. Again, it can take decades until chemicals are finally banned from the EU market under authorisation. Secondary raw materials are excluded from some obligations (e.g. registration) if they are defined as waste. New substances resulting from a recovery/recycling process have to be registered unless they have the same substance identity as an already registered substance. The registration of substances in preparations still remains an (unsorted) issue on the agenda of the European Commission and stakeholders who have to develop methods for their proper assessment.