All substances included on a HOCNF must fully comply with the relevant requirements of REACH. Suppliers are advised to follow the REACH compliance flowchart shown in Figure 1 in the Guidance on completing the HOCNF before they commission relevant tests or complete the HOCNF with existing data.
All substances in the chemical product used in the offshore processing of petroleum need to be listed on the HOCNF form. The following requirements regarding each substance are mandatory:
- full chemical name, molecular weight, CAS number (if available) and EINECS, ELINCS (if available) or REACH registration number of each of the substance in the product;
inorganic substances do not require submission of biodegradation or bioaccumulation data for HMCS registration
Substances, which are on the latest REACH Annex IV list or on the list for substances which Considered to Pose Little or no Risk to the Environment (PLONOR) do not require the submission of Persistence, bioaccumulation and toxicity (PBT) data for HMCS registration.
Substances on REACH Annex V do not always fulfil the same criteria as substances on REACH Annex IV therefore the OCNS team have right to justify the need for PBT data submission for specific product registrations.
To increase the efficiency of the registration process if petroleum distillates, solvent naphtha, recognised UVCB and surface active substances that are covered by REACH are contained in the product, suppliers are requested to enter the REACH registration number and quote the REACH registered name of those substances. Additional information such as levels of substitution (ethoxylation/propoxylation) in moles must be provided as well as trade names.