REACH Authorization Not Required for COD Cell Tests - Good News for Users and Producers

Initial ECHA Restrictions

COD (chemical oxygen demand) cell tests are highly beneficial for the analysis of water and wastewater as they combine accuracy with economy and ease of use. However, due to the potassium dichromate in their formulations, the tests have faced restrictions by the European Chemicals Agency (ECHA). According to the ECHA’s REACH regulations, prior authorization is needed for the production or use of the tests.

Constraints Eased for Scientific R&D

REACH regulations were later elaborated, exempting authorization for the use of the products for scientific R&D in a volume less than 1 ton per year. As per REACH Q&A 585, analytical activities, such as monitoring and quality control, are considered to be part of scientific R&D and, thus, are freely permitted. Still, unauthorized production was prohibited, thus sales of the reagents were threatened.

Producers Unite for Authorization

As authorization is a very costly and lengthy process, three German manufacturers of COD test kits (Merck KGaA, Darmstadt, Germany, MACHEREY-NAGEL GmbH & Co. KG, and Tintometer GmbH) founded the COD2 Consortium to jointly elaborate the application dossier for REACH authorization. This was required because, according to REACH Article 3 (23), the formulation step in the production of COD test kits was not covered by the exemption from authorization.

Latest Positive Developments

There was more progress in January 2015. REACH regulations were further expanded in Q&A 1030, exempting authorization for upstream steps, such as the formulation process in the production of COD test kits for use in scientific R&D. The COD2 Consortium considers this a very positive development. As they are no longer required to apply for authorization, they can secure the continuous production of COD test kits for water and wastewater analysis. This is good news for users and producers alike.

Learn More About REACH and COD

• COD2 Consortium Agreement
• Article from International Environmental Technology:
  COD Analysis and REACH Authorisation