Registration strategy for modified oils

Following the close of the pre-registration period on 1st December 2008, REVODS consortium members have carried out a detailed evaluation of substance identity and “sameness” for the chemically modified oils and fats that are subject to registration. Modified oils and fats may be grouped on the basis of either their source (for example: hydrogenated palm oil) or by alkyl chain descriptor as in the classification system that was developed jointly by the US Environmental Protection Agency and the Soaps & Detergents Association (referred to as the “SDA system”).

REVODS members have found the SDA system to be beneficial in determining equivalence in chemical composition for modified oils and fats from a wide range of sources, and to facilitate grouping under a limited number of alkyl chain descriptors.

REVODS consortium members therefore intend to support registrations for 3 glycerides by alkyl chain descriptor and/or a limited number of source-based modified oils and fats. The preliminary list of substances for which joint dossiers will be developed is provided below.

It is intended that dossiers for the following substances will be submitted to ECHA in time to meet the November 2010 deadline:

• 266-946-3 Glycerides, C8-18 and C18 unsaturated
• 268-084-3 Glycerides, C16-18
• 268-083-8 Glycerides, C16-22

It is intended that dossiers for the following substance will be submitted to ECHA in time to meet the 2013 deadline:

• 297-113-2: Oils, palm kernel, stearins, hydrogenated

In a subsequent communication to pre-SIEFs, the REVODS consortium will propose the formation of SIEFs for the registration of each of the 5 substances listed above. Please refer to the full letter to preSIEFs available for download below and the corresponding SIEF pages for more information.

New to the REVODS website is a section on the SDA system. Useful information on the application of this system to fats and oils can be accessed in this section.

Also available is a summary table detailing the source-base substances that will be registered under each of the three alky chain descriptors above.

• NOTE 1: The grouping in the REVODS modified oil registration table has been determined by each individual REVODS member company on their own substances. It is the obligation of all potential registrants to determine the correct alkyl chain descriptor for the substances that they intend to register, and not to assume equivalence of their substance with a substance produced by another Legal Entity.
• NOTE 2: Members of the REVODS consortium will not be submitting registration dossiers for any of the source-based modified oils and fats that are to be registered by alkyl chain descriptor. However, where registration is by alkyl chain descriptor, there will be reference in the joint dossier to the source-based substances that are defined by the alkyl chain descriptor.

For source-based substances that REVODS companies will not be submitting specific registration dossiers for, we invite potential registrants within the pre-SIEFs to consider adopting the SDA nomenclature approach and to determine the appropriate alkyl chain descriptor for their modified oil or fat.

Specifications for each of the modified oils and fats that will be registered by REVODS member companies will soon be issued as part of the sameness discussions and for adoption within each SIEF.