A cooperation of REACHECK Solutions, the Leading Registrant of Charcoal, and EBI has brought a breakthrough for BioChar in Europe. Soon BioChar can be registered under the existing REACH dossier of Charcoal. Known inter-European trade barriers for BioChar will therewith become history.
REACH (Registration, Authorisation and Restriction of Chemicals) has long created uncertainties within the biochar industry. Therefore, since its foundation, the European Biochar Industry Consortium (EBI) has put a lot of effort into clarifying the situation and bringing a clear legal status to BioChar traded in Europe.
Biochar is a chemically modified product from organic compounds, therefore REACH registration as an UVCB substance is mandatory for every producer placing biochar on the market.
There are existing REACH dossiers for charcoal made from wood (EC# 240-383-3) and coconut shells (EC# 271-974-4). Biochar from other types of feedstock are not registered yet, but, according to the European Chemicals Agency (ECHA), it is the producers’ duty to do so: „Companies need to register their substances and to do this they need to work together with other companies who are registering the same substance“. This means that either biochar producers have to join together to register their product, or they’d have to join an existing registry.
Fortunately, the BioChar Industry, due to the achievements of REACHECK Solutions and EBI, will not be forced to create its own REACH dossier, which would involve costs several 100.000 EUR, but will be allowed to join the existing charcoal dossier: https://echa.europa.eu/de/registration-dossier/-/registered-dossier/15550. The reason making this possible is a toxicological report initiated by REACHECK Solutions, that showed that BioChar and Charcoal from wood ends up in a very similar product and therefore suggests to allow BioChar to enter the Charcoal dossier. This report will be annexed to the Inquiry Dossiers of the individual Registrants. That being said, the final decision on the validity of the above described procedure lies within the responsibility of the European Chemicals Agency
(ECHA) in Helsinki.
This is great news as the Biochar Industry can now have legal certainty on their products without having to go through the very resource-intensive process of creating a separate Registration. As a result of our cooperation with REACHECK Solutions, EBI members are also entitled to certain discounts on the costs for the registration. However, the letter of access fee (depending on the tonnage produced per year) cannot be discounted.
Commercial buyers do not need to register but will soon face the obligation to only buy REACH registered BioChars. Producers with an annual production below one metric ton are exempted from the registration
obligations of REACH.
For further questions, please contact REACHECK Solutions directly or the EBI office under the contact data below.
REACHECK Solutions GmbH
Harald Bier EBI Office