ECHA (the European Chemicals Agency) has updated the list of chemicals “potentially subject” to REACH compliance checks (27/11/2017). This list includes “Red phosphorus” (EC# 918-594-3) which is used in a range of PIN flame retardant applications, and phosphine, a toxic gas chemically related to ammonia NH3 (PH3 – EC# 231-768-7 – confusingly listed as “phosphorus” by ECHA).
Inclusion on this list invites the Lead Registrant to update the REACH dossier, and may possibly if the compliance check is carried out, result in a requirement for further testing to complete available substance data. Compliance checks are meant to examine in general whether submitted dossiers from industry are satisfactory, so that inclusion on the list does is not related to possible future restriction of the chemical – this is a totally separate process (the CoRAP, Community Rolling Action Plan – see pinfa Newsletter n°90 for list of flame retardants currently on the CoRAP list). Also, white phosphorus (P4, also called “yellow” phosphorus) was added to the EU list of Critical Raw Materials (CRM) in 2017, joining phosphate rock which was included in 2014. The EU CRM list identifies 27 raw materials which are essential for different industries in Europe, for which Europe is largely dependent on imports. P4 is essential for a range of speciality chemicals including flame retardants, lubricants, agro-chemicals and pharmaceuticals and electronics, whereas phosphate rock is essential mainly for fertilisers and livestock feed. Inclusion of P4 on the CRM list will facilitate EU support for projects aiming to develop production in Europe, for example from secondary raw materials such as sewage sludge or animal by-product incineration ashes (see e.g. ICL RECOPHOS process).
ECHA “Substances potentially subject to compliance checks” 27/11/2018 https://echa.europa.eu/documents/10162/13628/substances_compliance_checks_en.pdf EU Critical Raw Materials List 2017 http://ec.europa.eu/transparency/regdoc/rep/1/2017/EN/COM-2017-490-F1-EN-MAIN-PART-1.PDF