The surface treatment of a substance is a “two dimensional” modification of
macroscopic particles. A “two dimensional” modification means a chemical
reaction between the functional groups only on the surface of a macroscopic
particle with a substance which is called a surface treating substance.
By this definition it becomes clear that this kind of modification means a
reaction of only a minor part (surface) of a macroscopic particle with the
surface treating substance, i.e. most of the macroscopic particle is
Therefore a chemically surface treated substance cannot be regarded as a
preparation nor be defined by the criteria of the "Guidance for identification
and naming of substances under REACH".
With the same reasoning, a chemically surface treated substance could not
be reported for EINECS nor be notified according to Directive 67/548/EEC
because it was covered by the separate EINECS entries of both the basis
substance (macroscopic particle) and the surface treating substance.
Taking this decision up under REACH means a consequent continuation of
former decisions. Using the same line of arguments, chemically surface
treated substances should not be registered as such under REACH, but the
following requirements should be fulfilled:
1. Registration of the basis substance (macroscopic particle)
2. Registration of the surface treating substance
3. Description of the use “surface treatment” in the registration dossier of the
surface treating substance and in the registration dossier of the basis
4. Any specific hazards or risks of the surface treated substance should be
appropriately covered by the classification and labelling and by the chemicals
safety assessment and resulting exposure scenarios.
แหล่งที่มา :ECHA_FAQ_version 2.3_2008-11-06
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