REACH AND AIS
Active substances manufactured for use in plant protection products only, and already included Annex I of 91/414/EEC (or pending inclusion in Annex I), are considered to be already fully registered under REACH. This obviates the need for the pre-registration, registration and conducting the chemical safety assessment, and no authorisation is required owing to the Annex listing and subsequent National Annex III authorisations. This does not
exclude active substances completely – all requirements related to information in the supply chain and downstream-user obligations are applicable and there is a possibility (albeit a small one) that restrictions could be imposed on a pesticide outside the scope of 91/414/EEC.
It is important to note that this provision only applies to substances within the EU’s plant protection product review process - it does not apply to pesticides that have failed to make it to Annex I listing, but are still being manufactured for export. It also only applies to substances that are used exclusively for plant protection and biocidal use; substances used for non-plant protection, or non-biocidal use, will still fall within the scope of the REACH registration process.
Although REACH does not apply to non-isolated intermediates, it applies to isolated intermediates and transported isolated intermediates. There is, therefore, no specific exclusion for intermediates for plant protection actives, although the registration process for intermediates is much simpler than for other substances in the scope of REACH.