Researching or developing a chemical product or process in the EU may bring you face-to-face with PPORD notification, the Product and Process Oriented Research and Development. Below is a quick overview of what PPORD notification is, when it applies, how to handle it and how Chementors can help. 

Definition and Purpose 

Article 9 of the REACH Regulation (EC) No 1907/2006 provides a five-year exemption from REACH registration duties for substances manufactured in the EU or imported there for product- and process-oriented research and development. This exemption applies to manufacturers, importers, or producers of articles, either on their own or in cooperation with listed customers, regardless of the tonnage band and whether the substance is new or already on the market. To qualify for this registration exemption, companies must submit a PPORD notification to ECHA. The purpose of PPROD is to support innovation as long as the substance meets all required conditions.  

When does the PPORD notification apply?

The scope of the PPORD definition is very broad and covers any development, testing, or use of a substance to generate information. You might need a PPORD notification if, for example: 

• You are developing a new substance, a new mixture, or an article 

• You are developing a new use for an existing substance 

• You are testing performance during process or product development

• And so on

PPORD has a very wide scope. If you are not sure whether your project qualifies for all conditions to apply for PPORD, let our experts help you determine this.  

What are your obligations under PPORD? 

Even though the PPORD notification gives some flexibility, especially in terms of saving registration cost and time, there are still strict obligations to fulfil in order to benefit from this registration exemption, which include, but are not limited to: 

• Notification to ECHA of the PPORD activity by submitting a PPORD notification 

• Documentation of your R&D scope, volumes, duration, and safety measures 

• Ensuring that exposure is controlled, risk is assessed appropriately for the scale of your R&D 

• Ensuring that the substance is not made available to the general public at any time on their own, in a mixture, or in an article 

• Etc., 

  

Risks & Limitations

The PPORD notification is not simply paperwork that is done to get the exemption. It is the company’s legal duty that all the project’s activities stay compliant with the PPORD conditions. If any activity involves quantities that are not within the PPORD scope, companies must register those quantities under REACH.  Also, failure to properly notify or document your PPORD can lead to non-compliance.  Finally, regulatory definitions continue to evolve. EU authorities may respond with a closer look and stricter conditions of the PPORD if the line gets blurry between genuine research activities and commercial use, or if the exemption is used incorrectly.  

How Chementors can support your PPORD needs 

Navigating PPORD can be tricky. Insufficient application or non-compliant data leads to the risk of failing the ECHA assessment or facing an ECHA administrative charge. Chementors has extensive experience handling a wide range of PPORD notifications. We offer a PPORD service that handles the complete process: 

• Determining whether your planned activity qualifies for PPORD notification 

• Assessing and developing all supporting documents to fulfill and comply with PPORD requirements 

• Preparing and submitting the PPORD notification with full compliance 

• Advising on whether your R&D may transition into commercial use: when to exit PPORD and prepare for REACH registration 

  

Ready to explore your PPORD options?

Get in touch with Chementors to discuss how your project might qualify under PPORD, and how to maintain your regulatory compliance while keeping your innovation on track.