Substance identity - 

UVCB substances

Lead registrant workshop 2nd February 2012

Steven BuchananUnit C2 – Substance identification and data sharing
Aims of this presentation

• To highlight how elements of UVCB subs

(SID) should be presented in the dossier

3⁄4 ... by providing some practical advice• To help lead registrants to understand w

requires certain UVCB SID information 

3⁄4 ... and to what level of detail 
What is a UVCB substance? 

• Substance of 

Unknown or 

Variable compo

reaction products or 

Biological materials

• Cannot be sufficiently identified by its ch

composition, because:

• The number of constituents is relatively large and/or• The composition is, to a significant part, unknown and/or• The variability of composition is relatively large or poorly pre

• If the chemical composition of, for exam

reaction product is known 

3⁄4Identification either as mono- or multi-constitue

be considered
Appropriateness of EC/CAS identi

9 Only assign an EC/CAS identifier that fits 

substance

9 Check carefully whether a certain EC/CAS 

is specific to your substance 

9 Make sure it does not cover multiple subs9 In EINECS there are published descriptio

part of the substance identity –where the

used you should check whether your subthis description 
IUPAC name for UVCB substances 

• IUPAC rules cannot be easily applied to U• Consequently the term “IUPAC” is not so • However, a “substance” name should be • The naming of UVCB substances is specif

type

• Broadly addressed in the ECHA guidance • More detailed guidance on naming of spe

UVCB substance can be sought from the trade association
Description of manufacturing proc

9 In addition to chemical composition UVCB s

require information on source/manufacture

9 To be provided in the description field of se

section 3.1, or as an attachment in section 

9 Forms part of the substance identity - any 

change may lead to a different substance i

9 Should be provided in as much detail as po

9identity of starting materials/source (and ratio)9reaction steps/mechanisms9plant operating parameters (e.g. temperatures/pressu9solvents/reagents used 9details of any clean-up/purification steps 

9 Should be specific to the registered substa[Avoid a cut and paste of an EINECS descrip
Example of a description of a manufacturing process

1. An aqueous solution (...%) of A is acidifi

of acid X in a 1:1 molar ratio to form B. 

2. This solution is then reacted with C, whi

dissolved in solvent Y, in a 1:2 molar ra

3. This 2-phase reaction forms the substan

dissolved in solvent Y. 

4. The aqueous layer is separated and disp5. The substance D is purified by distillatio
Constituents of UVCB substances

9 Individual constituents > 10 % (w/w) or relev

and/or PBT assessment need to be specificall

9 Constituents < 10 % (w/w) which have been 

identified should be reported separately or as constituent

9 Constituents which cannot be specifically iden

an extent unknown should be identified as fareported in generic terms 

9 It is important that close to 100 % accountab

substance composition is achieved
Example of how to present generconstituents and concentration ra

• A hydrocarbon-based UVCB substance ha

analysed and contains > 50 constituents are > 10 % in the chromatogram. The generically presented the composition as 

• Linear alkanes (C20-C32) 60-80 % w/w• Branched alkanes (C20-C25) 20-35 w/w• Cyclic alkanes (C20-C25) 0-5 % w/w
Concentration ranges for constitu

9 Always specify: for each specific and generic 

in section 1.2

9Minimum and maximum value (with units)

9 Realistic: based on knowledge of production 

9They should not be overly broad

9 Variability is an element of the definition of U9 It assists ECHA in performing its tasks under 

data sharing
Spectral data and analytical inforfro UVCB substances

• Establishes the presence and absence of 

of constituents

• Registrants should not limit themselves t

of techniques listed in Annex VI 2.3.5 an

• Where more information can be provided 

not listed in Annex VI section 2, this info

be included
Waiving of spectral data and analinformation

• If it is not technically possible or if it do

scientifically necessary to give information 

of the items listed in Annex VI, the reasons 

stated (Annex VI, Section 2)

[The fact the substance is a UVCB is not a jus

waiving 

9 Important that these reasons are robust in th

presented as scientifically-based justification

9 A more comprehensive analysis has been gai

alternative technique to those listed in Annex 

9 However, it is still important that where the l

are not applied the reason is explained

9 Any justification for waiving will be assessed 

and consequently may not be accepted as va
Example of a justification for waivspectral data

• A company produces a crystalline inorga

substance.

• The company considers that the list of sp

Annex VI 2.3.5 is not the best way to idesubstance but instead applies elemental 

as well as XRD and IR spectral analyses. 

• These analyses characterise the substanc• In addition the company waives NMR and 

analysis based on the substance structurthat more appropriate techniques have binstead. 
Key messages for substance iden

 Information in the dossier should be sufficien

to conclude on an unambiguous substance 

 All information should be clear, concise and 

contradictory

 Supplementary information can be attached  ECHA does not have the same objectives wit

spectral data and analytical information

 ECHA does not possess factual knowledge ty

to industry

 Support:

The inquiry TCC tool can be applied to your dossierDSM Part 18 and the ECHA SID Guidance should be us

preparation of your registration dossier. 
Thank You!

Steven Buchanansteven.buchanan@echa.europa.eu