We receive a lot of interesting questions daily. I got this message just recently:
“Dear Luka,
I have found your details on Bens-consulting where you reply to a question that relates to chemical agents without CAS number.
My question is a little bit different, but I do not seem to be able to find the answer on the web...
My understanding is that items are designated under a CAS registry number based on the chemical makeup. If my understanding is correct, if an item is recorded with a CAS number, then it would be considered registered under the REACH regulation regardless of the supplier?”
If this is also something you’re struggling with, then my answer could come useful. Here’s what I wrote back, word by word:
“In general, a CAS number is assigned to a substance by the Chemical Abstracts Service.
If a substance is assigned a CAS number, it does not mean it is automatically registered under REACH regulation*.
*Regulation (EC) No 1907/2006 of the European Parliament and of the Council of 18 December 2006 concerning the Registration, Evaluation, Authorisation and Restriction of Chemicals.
Registration of a substance under REACH is an entirely separate procedure.
Hope this was helpful.”
Furthermore, depending on your company’s role in the supply chain (manufacturer, downstream user, importer) you may have different obligations according to the regulation.
If your company needs help with determining your obligations in accordance with REACH regulation or maybe already needs to register a specific substance, then writing to me at info@bens-consulting.eu is the best thing you can do.
Why wait and struggle if you have solution right in front of you.
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