Position Paper: Exposure Scenarios for Mixtures / Extended SDS for Mixtures

The EU REACH Regulation requires that substance registrants complete a chemical safety assessment (CSA) and document this in a chemical safety report (CSR) for all substances manufactured or imported at 10 tonnes or more per year per registrant (Article 14 REACH).

This CSA must be performed and documented in the CSR according to the ‘General provisions for assessing substances and preparing chemical safety reports’ (Annex I REACH) for substances on their own, substances in mixtures and substances in articles. The legal text does not require exposure scenarios to be prepared for mixtures themselves. However, formulators for example have a legal obligation (Article 31.7 REACH) to forward to their customers information relevant to exposure to their mixtures, which they have obtained from the exposure scenarios (ES) attached to the SDSs for their ingredient substances.

The automotive industry associations ACEA, CLEPA, JAMA, JAPIA and KAMA support the concept for mixtures of integration of substance ES information into the core Sections 1-16 of the mixture SDS whenever possible, and request that this approach is followed throughout the supply chain.

Furthermore, the automotive industry associations above wish to draw attention to the obligation of suppliers to check ES of their mixture ingredients in order to provide advice on safe use of chemical product to their end-users. For this reason, suppliers of chemical products must confirm that the identified uses of themselves and of their customers are covered by the incoming ES of the single ingredients.