REACH provisions for articles

REACH knowledge base – REACH provisions for articles

Tasks related to SVHC substances in articles

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

Notification obligation

The article contains an SVHC substance based on Annex XIV
Its volume exceeds 1 tonne/year (the given substance in all articles of the manufacturer or importer combined)
It volume exceeds 0.1% per article (in case of articles composed of several articles, for each component)

Exemption from 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 (even in the disposal phase!) and we can prove that

Obligation to provide information

The article contains an SVHC substance based on Annex XIV
It volume exceeds 0.1% per article (in case of articles composed of several articles, for each component)

Exemption from 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 equal to the consumer) at the same time as delivery
Consumers should be informed only on request (we have 45 days to do so from receiving the request)
Information to be shared: name of the substance and, if available, instructions on safe use of the substance and other “relevant” data

Rules for REACH registration in 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 given articles the substance is present in a quantity that exceeds one tonne per year*
The substance is intended to be released under normal or reasonably foreseeable conditions of use (intended release** happens during its intended use)

* In calculating the quantity, it is necessary to calculate not only the quantity of the substance 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 the interpretation of the statement above:

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

However, we may be exempted if someone has registered that substance (you can check the pre-registered or actually registered substances on the website of the Agency).