Originally, EC 240-383-3 applied only to charcoal produced from pure wood. With the expansion of the substance definition, it is now possible to register pyrolysis charcoal derived from various organic materials. This also requires more information to be included in the dossier. However, the resulting additional costs are borne only by those companies that use the expanded substance definition for registration, which leads to a price surcharge for biochar. For this reason, there are slightly different LoA prices for charcoal and biochar.
As soon as the registrant decides to cease the manufacture or import of a substance, the registration in REACH-IT must be set to inactive. ‘Inactive’ registrations can be re-activated by clicking on ‘Restart manufacture or import’ in the ‘Reference number page’. Once the registration has been reactivated, the registration dossier update can be submitted to ECHA. This must be done before the actual manufacture or import is restarted.
Note in accordance with the registration guidelines: The legal consequences of the cease of manufacture differ depending on whether ECHA is notified of the settings while ECHA processes an evaluation decision or outside of that period. If the cease of manufacture or import is notified to ECHA after a draft evaluation decision has been notified to the registrant and before the decision is adopted, the registration is no longer valid (Article 50(3)) and its status is marked as ‘invalid’ in REACH-IT. If the registrant informs ECHA of the cease of manufacture or import outside of the time an ECHA evaluation decision is being processed (Article 50(2)), the registration is deactivated and its status is marked as ‘inactive’ in REACH-IT.
Note in accordance with the registration guidelines: The legal consequences of the cease of manufacture differ depending on whether ECHA is notified of the settings while ECHA processes an evaluation decision or outside of that period. If the cease of manufacture or import is notified to ECHA after a draft evaluation decision has been notified to the registrant and before the decision is adopted, the registration is no longer valid (Article 50(3)) and its status is marked as ‘invalid’ in REACH-IT. If the registrant informs ECHA of the cease of manufacture or import outside of the time an ECHA evaluation decision is being processed (Article 50(2)), the registration is deactivated and its status is marked as ‘inactive’ in REACH-IT.
REACH registration is usually the process by which manufacturers and importers fulfil their legal obligation to register imported and/or manufactured substances with the European Chemicals Agency (ECHA) in accordance with the REACH Regulation.
Certification can be a sub-process of the conformity assessment of a product or other evidence of compliance with a given requirement or standard. In general, certifications are mostly temporary and are issued by accredited (private sector) certification bodies.
Certification can be a sub-process of the conformity assessment of a product or other evidence of compliance with a given requirement or standard. In general, certifications are mostly temporary and are issued by accredited (private sector) certification bodies.
Substances, substances in mixtures or, in individual cases, substances in articles are registered. These are not finished products (articles), but only their chemical ingredients or components. Trademarks or companies cannot be registered under REACH.
Compilation of substance information mostly in the form of predefined test reports and process descriptions. Preparation of a inquiry dossier using IUCLID software. Acquisition of a Letter of Access, joining a joint submission in REACH-IT, submission of a registration dossier, payment of the registration fee, receipt of the registration number.
Registration procedure
Registration procedure
Costs are usually incurred vis-à-vis
- ECHA: in the form of registration fees (depending on quantity and company size);
- The lead registrant (or consortium): in the form of the letter of access + an administrative fee, if applicable;
- Optionally, a service provider: in the form of laboratory, consultancy and REACH registration services.
Follow-up costs arise when the registration quantity is changed. These are pro rata ECHA fees, LoA costs and, if applicable, costs for service providers.
To change information on chemical data and their uses, the tonnage band or the company, the registration dossier must be updated without undue delay (Administrative update - 3 months; Complex update - 3, 6 or 9 months)
In certain cases this is foreseen. These cases are described in an ECHA practical guide.
ECHA practical guide
ECHA practical guide
As long as no exemption exists, those (ingredients) substances that are produced or imported in quantities of one ton or more per calendar year must be registered.
More information
More information
For EC No 240-383-3, the definition in the previous EINECS registry is still valid: “An amorphous form of carbon produced by partially burning or oxidizing wood or other organic matter”. The biochar can be registered if the analysis results correspond to the extended substance identity profile (SIP) and the specified concentration ranges of the constituents are met. Depending on the used starting materials, additional studies can be required to confirm consistency with the extended SIP and to exclude classification according to Regulation (EC) No 1272/2008 (CLP).
At present, we recommend for the registration the use of our Expert Statement on biochar for REACH purposes. An extended SIP in the Joint Submission is in preparation.
At present, we recommend for the registration the use of our Expert Statement on biochar for REACH purposes. An extended SIP in the Joint Submission is in preparation.
The substance is categorized as UVCB substance (“Unknown or variable composition, complex reaction products or biological materials”) by the European Chemicals Agency (ECHA). UVCB substances are described by a combination of the starting materials and manufacturing process. Analysis results show that the main constituent of products, which arise from pyrolysis of biomass as a consequence of carbonization, is chemically similar also when different starting materials are used. Hence, properties such as porosity or rather specific surface area may vary.
According to Article 2 of Regulation (EC) 1907/2006, additional legislation may regulate the use of a substance. Therefore, it should be checked on an individual basis whether the registered use of a UVCB substance, which is manufactured from specific starting materials, is permitted. For example, Regulation (EC) 2019/1009 determines that only biochar from certain starting materials is allowed to be used as additive to fertilizers.
Charcoal produced from wood or other plant material must be transported in accordance with ADR and IMDG Code regulations for UN number 1361 (dangerous goods class 4.2 – spontaneously combustible materials, at least packaging group III). Due to frequent accidents, Special Provision 978 for maritime transport stipulates that, from 2026, it is not allowed to use UN test N.4 to exempt charcoal of vegetable origin (UN 1361) from the provisions of this code. The transport document must contain the following additional information: date of manufacture, date of packaging, temperature of the substance on the day of packaging (in packages).
In general, we can recommend that the dry charcoal condition is decisive for determining the tonnage range.
The following should also be considered:
During transportation and sale of the biochar, the total moisture content should generally not exceed 10% due to the increased risk of spontaneous ignition of moist charcoal. On the one hand, an increased water content of charcoal or biochar reduces dust formation and thus the risk of inhaling dust. On the other hand, an increased water content can promote spontaneous ignition. For this reason, the recommendation for sea freight (cargo shipping) is that the water content should not exceed 10%. In case of doubt, a test according to UN N.4 should be carried out.
The following should also be considered:
During transportation and sale of the biochar, the total moisture content should generally not exceed 10% due to the increased risk of spontaneous ignition of moist charcoal. On the one hand, an increased water content of charcoal or biochar reduces dust formation and thus the risk of inhaling dust. On the other hand, an increased water content can promote spontaneous ignition. For this reason, the recommendation for sea freight (cargo shipping) is that the water content should not exceed 10%. In case of doubt, a test according to UN N.4 should be carried out.