Registration of DTL products and derivatives
One of the objectives of IEA Bioenergy Task 34 (biomass liquefaction) is to facilitate commercial deployment of Direct Thermochemical Liquefaction (DTL) technologies. A very important and sometimes underestimated step in commercialization of new chemicals and substances is mandatory registration of the new products, and its related cost. This report provides further information and guidance on the registration of DTL products and derivatives.
The liquid products from Direct Thermochemical Liquefaction process may require registration as a chemical substance to allow introduction on the market. Different registration systems are in place around the world but have in common that they all aim to better protect human health and the environment. Important part of any registration is the proper description of a substance including chemical, physical and toxicological data. The Global Harmonized System (GHS) was developed by experts from the United Nations (UN) as a universal system to replace different national systems to eliminate mutual misunderstandings and confusion in interpretation of hazard classifications, labels, or Safety Data Sheets (SDS) and thus create more unity.
Different substance registrations systems exist like the American TSCA and the European REACH. The latter one is described in some more detail in the report. REACH – Registration, Evaluation, Authorisation and restriction of Chemicals – is an obligatory registration for any chemical substance produced or imported in Europe at quantities above 1 t/a. In the registration a distinction is made in the annual produced or imported tonnage of that substance: tonnage bands are: 1-10 t/a, 10-100 t/a, 100-1000 t/a and >1000 t/a. Fees for registration will increase with increasing tonnage band, but more important also additional substance data should be provided which can become very costly. For the lowest tonnage band, total costs can be in the order of 50 – 150 k€, whereas for the highest tonnage band it can increase to over a million euro.
To support the development of new products a special registration was introduced in REACH called PPORD – Product and Process Orientated Research and Development. It is a simplified registration allowing to perform product testing at any scale and the dossier is confidential. A limitation is that the products from testing cannot be sold, and in principle they need to be recollected and destroyed after the evaluation phase.
The REACH database has been searched for registrations of DTL products. Only a few could be found, being fast pyrolysis bio-oil and fractions thereof.