Borderline between preparations/articles for steel and steel products

In view of its importance, EUROFER has assigned a dedicated area of its website to this topic. EUROFER has reviewed the ECHA Guidance on substances in articles and determined that, in accordance with the REACH definition of an article, steel semi-finished articles (with the exception of as cast ingots) are articles under REACH.

While Copywrite is retained with respect to our position paper entitled “EUROFER position paper determining the borderline between preparations/articles for steel and steel products”, you are invited to use the two documents listed below in any communication with EU Member State REACH Helpdesks and Inspection Authorities.

• EUROFER position paper determining the borderline between preparations/articles for steel and steel products. This paper has been developed in close co-operation with the worldsteel (formerly the International Iron and Steel Institute) and is supported by the global steel industry in so far it applies to European law.
  EUROFER position paper determining the borderline between preparations and articles for steel and steel products. 28 October 2008.pdf 309.89 kB
• ECHA letter dated 02/09/09 that acknowledges the content of the EUROFER position paper.
  Reply ECHA on EUROFER letter. 2 September 2009.pdf 418.03 kB

It is our recommendation that importers of steel semi-finished products maintain a copy of these two documents available for visits from EU Member State Inspection Authorities and that your company maintains a written record of the rationale for non-registration of the substances in steel semi-finished products to accompany these documents.