PPORD Notification Made Simple: Unlocking EU REACH Exemption for Innovation
What Is PPORD Notification
According to Article 3 (22) of the REACH Regulation, PPORD is defined as “any scientific development related to product development or the further development of a substance, on its own, in preparations or in articles in the course of which pilot plant or production trials are used to develop the production process and/or to test the fields of application of the substance”. Any scientific development of a substance consisting of, for example, campaign(s) for the scaling-up, improvement of a production process in a pilot plant or in full-scale production, or the investigation of the fields of applications for that substance, falls under the definition of PPORD irrespective of the tonnage involved. To promote innovation, the REACH Regulation exempts substances produced or imported in quantities exceeding 1 tonne per year for PPORD purposes from registration obligations, provided a PPORD notification is submitted. However, obligations such as authorization, restriction, and Safety Data Sheet (SDS) requirements must still be fulfilled.
How to Complete PPORD Notification
To be exempt from the obligation to register a substance used for PPORD, a PPORD notification must be submitted to the European Chemicals Agency (ECHA). The exemption period is 5 years, with the possibility of applying for an extension if necessary. The substance may only be used by the customers listed in the PPORD notification for the notified activities.
PPORD Notifier
- EU Manufacturer
- EU Importer
- Only Representative (OR)
Information Requirements
- Identity information of the notifier
- Substance information, including identification analysis and hazard classification
- PPORD activities information, including estimated tonnage and the list of customers
- ECHA may require the notifier to provide additional information and impose specific conditions of use
Considerations Before Making a PPORD Notification
Before submitting a PPORD notification, the company must confirm that the activity, conducted alone or in cooperation with listed customers, falls within the scope of PPORD and maintain all necessary information to fulfill its duties under REACH.
- Ensure that the substance is manufactured or imported for the purpose of PPORD only; if used for other purposes, registration is still required.
- Ensure that only the notifier and listed customers have access to the substance, and the substance is not made available to the general public at any time
- Develop appropriate risk management measures to ensure the substance is handled in reasonably controlled conditions, in accordance with the requirements for the protection of workers and the environment
- Ensure the users keep well track of quantities of substance used in the PPORD, and the remaining quantities are recollected for disposal(unless registered). Provide documentation (e.g., shipment documents, disposal documents, information on process losses, etc. ) when necessary.
Our Services
- PPORD Compliance Analysis Service
- PPORD Notification Service
- Only Representative Service
- REACH Registration Service
