Aluminium REACH Consortium

URGENT: To all co-registrants of the substances:

Aluminium (CAS 7429-90-5)

Aluminium oxide (CAS 1344-28-1)

Aluminium hydroxide (CAS 21645-51-2)

The European Union has imposed sanctions on Russia in response to the war in Ukraine, notably through Council Regulations (EU) No 269/2014 and No 833/2014. These measures include individual sanctions, economic sanctions, and visa restrictions. To date, 1,473 individuals and 207 entities have been sanctioned. These sanctions affect Lead Registrants and REACH Consortia, as no trade or economic support with designated persons is permitted. This includes sharing data, studies, or submitting registration dossier updates. EU sanctions act as lex specialis over the REACH Regulation (EC) No 1907/2006. Where REACH obligations conflict with sanctions, sanctions take precedence. Submitting a dossier or update involving a co-registrant who is sanctioned—or owned or controlled by a sanctioned person—would violate Regulation (EU) No 269/2014, even if required under REACH. To comply with sanctions and fulfil REACH obligations, the identity of all co-registrants must be verified before any joint dossier update. As this cannot be done by the Lead Registrant alone, co-registrants must provide the required information promptly. All co-registrants must therefore confirm: 1. That neither the registrant nor its directors are subject to sanctions under Council Regulation (EU) No 833/2014. 2. For Only Representatives: that the non-EU manufacturer and its directors are also not subject to these sanctions. Please send this information to harlow@european-aluminium.eu [a template declaration is available on request]. Without this information, the Lead Registrant cannot submit mandatory dossier updates and will inform ECHA of any registrants who have not provided the required confirmation by Friday, 28 November 2025.

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