REACH provisions for articles

REACH knowledge base – REACH provisions for articles

Tasks related to SVHC substances in articles

Obligation to notify the Agency (ECHA)
Obligation to provide information to customers

Notification obligation

The article contains an SVHC substance on the Candidate List
Its total quantity exceeds 1 tonne/year (the given substance in all articles of the manufacturer or importer combined)
Its concentration exceeds 0.1% w/w in the article (in the case of complex articles, for each component article)

Exemption from the notification obligation

If one of the above criteria is not met
If the substance in question has already been registered for that identified use
If exposure can be excluded (including during the disposal stage) and this can be demonstrated

Obligation to provide information

The article contains an SVHC substance on the Candidate List
Its concentration exceeds 0.1% w/w in the article (in the case of complex articles, for each component article)

Exemption from the obligation to provide information

If one of the above criteria is not met.

Rules on the obligation to provide information regarding SVHC substances

It is mandatory to inform customers (not the same as consumers) at the time of delivery
Consumers must be informed only upon request (within 45 days of receiving the request)
Information to be provided: the name of the substance and, if available, instructions for safe use of the article, as well as other relevant information

Rules for REACH registration in the case of articles

Registration of substances in articles is required when all conditions listed under Article 7 of the REACH Regulation are fulfilled:

In the articles concerned, the substance is present in a quantity exceeding one tonne per year*
The substance is intended to be released under normal or reasonably foreseeable conditions of use (the intended release** occurs during use)

* In calculating the quantity, it is necessary to consider not only the quantity of the substance intended to be released, but also its total quantity in the article.

** The intended release does not occur during the primary function of the product.

Examples for interpreting the statement above:

The release of ink from an ink cartridge used in a printer is not included, as it is the primary function of the article
The release of fragrance from a perfumed paper tissue is included
The release of nicotine from a nicotine patch is not included

However, we may be exempt if someone has already registered that substance (you can check pre-registered or registered substances on the Agency’s website).