The Ethanol REACH Association (EtOH-REACH) enables manufacturers and importers to jointly submit high-quality dossiers. Through membership of the Association or the purchase of an Letter of Access, companies can participate in the ethanol, fusel oil and/or vinasses joint submissions and will not have to produce the full dossiers themselves.
According to Regulation (EC) No 1907/2006 concerning the Registration, Evaluation, Authorisation and Restriction of Chemicals (hereinafter called ‘REACH’), Ethanol will need to be registered by all its EU based manufacturers and importers and all the only representatives of its non EU based manufacturers and formulators, within the deadlines prescribed for their respective volume bands.
Registration of a a high tonnage, data rich and widely used substance such as ethanol implies submission of a complex and expensive to produce dossier. Joint submission of one single dossier by registrants of the same substance is legally possible and officially encouraged. Producing one single dossier allows sharing of costs and other burdens by the registrants. Considering the many legal implication of such cooperation between registrants, this cooperation needs to be formally organised.
Since there are several hundred registrants for Ethanol, an association is the most efficient form for this formal organisation of the cooperation and legal relationship between potential registrants for this substance. The association aims to have amongst it membership all the members of the Ethanol SIEF.
During the production process of Ethanol intermediates and by-products occur. These substances may also need to be registered under REACH. Where this is the case, cooperation between Ethanol manufacturers that need to register these substances will be facilitated by the existence of a well organised association. For now the association facilitates the registration of Fusel Oil and Vinasses.
The Ethanol REACH Association was founded by Abengoa Bioenergy, Bauche Energy, CropEnergies, INEOS, Royal Nedalco and Tereos. The three European ethanol interest associations, eBIO, IEA and UEPA, are also active participants.