Colloquially, when we talk about chemical products, we think about substances or mixtures that have been manufactured in large factories which emit smoke from their tall chimneys. But in reality, we are surrounded by countless chemical substances and mixtures every day, some of which we are not even aware of.
What is an article?
All substances and mixtures can be combined to form different materials which we use to build objects with the aim of making our day-to-day lives easier; for example, a smartphone with a more durable battery, a lighter aeroplane or an item of clothing that doesn’t crease.
In accordance with the REACH Regulation, we call these objects articles: an object which during production is given a special shape, surface or design that determines its function to a greater degree than its chemical composition. The complexity of these objects increases when we combine several articles to create what we call a complex object.
For example, a bicycle is a complex object that is formed from many different articles, as shown in the illustration below:
What obligations have been established by REACH with regard to articles?
The REACH Regulation has established certain obligations for companies that produce, import and/or market articles:
- Communication in the supply chain
All European companies that market an article in Europe must confirm whether the article in question contains any substances of very high concern (SVHC) that are included in the candidate list of substances for authorisation at concentrations higher than 0.1% m/m.
If that is the case, the company is obliged to notify all recipients of the article about the substance(s) included in the candidate list and provide them with necessary information about how to safely use the product.
- Notifications about substances present in articles
Companies that produce and/or import articles are obliged to notify ECHA of any substances:
- That are of very high concern (SVHC) and that are included in the candidate list of substances for authorisation.
- That are present in the articles that the companies produce and/or import at concentrations of < 0.1% m/m.
- Whose total annual substance quantity is higher than 1 tonne per year.
- REACH Registration
Companies producing or importing articles must register in REACH any substance contained in an article, on the condition that the following two conditions are complied with:
- The substance is intended to be released by the article within its normal conditions of use.
- The total amount of substance present in the produced or imported articles from which said substance is to be emitted is higher than 1 tonne per year.
However, if the producer or importer of an article can provide documentary evidence that the substance has already been registered by another company for the same use, they will not have to submit their own REACH registration.
It is important to remember that companies that market articles must also comply with the obligation of notifying the SCIP database, in accordance with waste regulations, and in turn they may have to comply with other REACH requirements as downstream users or formulators, for example.
