Keith is a HS&E Manager at a UK steel processing company that manufactures 'merchant bar' from steel 'billet', supplied from Spain, Norway and Turkey.  Keith has been charged with ensuring the company's compliance with REACH and has undertaken some background reading on this complex subject.  He understands his obligation as a downstream user for the substances/preparations his company uses as part of its manufacturing process.  However, he remains confused as to whether the semi-finished (as-cast) steel he uses as his manufacturing feedstock is considered a preparation or article under the requirements of REACH.

Keith understands that if the large quantity of billet his company purchases (>30,000 tonnes) is determined a preparation, he would be subject to register the iron and non-ferrous metals within the steel he 'imports'.  He recognises that the obligation to register would only extend to the steel imported from Turkey, and not that from within the EU (Spain) and European Economic Area (which includes Spain and the other countries within the EU27 and Norway, Iceland, Lichtenstein). If the billet were considered an article, and because there is no intended or foreseeable release, then no registration would be necessary.

Having contacted his national association (UK Steel) Keith discovers that the European Iron and Steel Federation's (EUROFER) position on this issue is that all semi-finished (i.e. slab, bloom, billet, machined and dressed ingots) and final steel products are articles, and are therefore exempt from the requirements of registration.  This position, which is supported by the global steel industry in so far as it applies to EU law, was determined from the European Chemical Agency's "Guidance on substances in Articles", where it can be clearly argued that semi-finished steel products have a special shape, surface, or design which determine their function to a greater degree than do their chemical composition.

This position assumes that semi-finished steel products are re-shaped into finished steel products.  No where in the manufacturing chain is the semi-finished product re-melted (i.e. back to a preparation).  Were this to happen then the article-article chain would be broken and registration obligations may apply.  The position also recognises that only machined and dressed ingots satisfy the definition of an article.  Cast ingots are considered preparations.