Is my product an article under REACH? Under the REACH Regulation, not only substances and mixtures are subject to regulatory obligations. Articles may also be affected, particularly when they contain Substances of Very High Concern (SVHCs) or are designed to release substances during normal use.
However, one of the most common challenges for companies is determining what qualifies as an article and when REACH obligations apply.
REACH defines an article as an object that is given a specific shape, surface or design which determines its function to a greater degree than its chemical composition.
In other words, articles are products whose function is primarily determined by their shape or intended use rather than by the substances they contain.
Common examples of articles include:
In all these cases, the product’s function is determined by its design rather than its chemical composition.
It is not always easy to distinguish an article from a substance or a mixture. For example:
Paint → mixture
Detergent → mixture
Perfume → mixture
However, these mixtures may ultimately become part of an article. In other words, some products may consist of a combination of an article and a mixture.
Some products cannot be easily classified as articles and require a more detailed assessment. These are known as borderline cases, which are addressed in ECHA’s Catalogue of Borderline Cases Between Articles and Substances/Mixtures, published in May 2025.
Typical examples include:
In such cases, it is necessary to assess which element determines the product’s primary function and how any substances are released during use.
Correctly identifying whether a product is an article, a mixture or a combination is essential because it determines the applicable REACH obligations, including:
Failure to correctly identify the nature of a product may lead to regulatory non-compliance and risks to market access.
Since many products do not fit clearly into a single category, ServiREACH helps companies to:
Articles are also subject to REACH, but correctly determining their status is not always straightforward.
A proper assessment helps companies ensure compliance, minimise regulatory risks and make informed decisions about their products.
Consultant at ServiREACH with an environmental profile and REACH specialist. I support compliance projects, documentation, and decision-making for operating in the EU.
