ECHA Issues Guidance to Help Manufacturers Comply with PAH Restrictions Under REACH
The ECHA has published a guidance document providing general considerations on the scope of restrictions on PAHs in consumer products. The document also includes examples of products and components falling inside and outside the restrictions.
- (1888PressRelease) May 06, 2018 - On March 7, 2018, the European Chemicals Agency (ECHA) published a guidance document to assist the consumer products industry with compliance against restrictions on polycyclic aromatic hydrocarbons (PAHs) under entry 50 of Annex XVII of REACH.
This non-legally binding document contains:
• ‘Stepwise approach’ to assess whether an article falls under the scope of the restrictions
• Non-exhaustive list of article and subtypes considered inside and outside the scope of the restrictions
A full list of examples of articles and components in articles, that are considered to fall under the scope of restriction, can be found in Annexes 1 and 3 of the guideline. Annex 3 contains thirteen illustrative examples. Annex 2 of the guideline contains examples of products considered to be outside the scope of restriction.
Examples of articles and components that should be considered within the scope of the restriction due to the possibility of direct as well as prolonged or short-term repetitive contact with the skin or oral cavity, include:
• Clothing, footwear, gloves and sportswear – e.g. underwear, footwear (not underside), rucksacks/backpacks
• Household utensils, trolleys and walking frames – e.g. crutch and walking stick handles, cookware handles, plastic mugs, table cloths
• Sports equipment – e.g. turf filaments, frisbees, bicycle handlebars, dumb-bell handles, canoes
• Toys and childcare articles – e.g. changing mats, bicycles, plastic swords, accessible parts of baby walker, painting articles
• Watch-straps, wrists-bands, masks, head bands and similar articles – e.g. combes, headbands, umbrella handles, earplugs
• Miscellaneous – e.g. back rests, caps for writing instruments, carpets
A more exhaustive list of examples can be found in Safeguards 053/18.
The guideline states that PAHs may be present in the following materials used in consumer products:
• As a natural contaminant in mineral oils and coal-based extender/plasticizer oils – used in the manufacture of rubber and plastic
• Carbon black (soot) – intentionally added to elastomers to give characteristics such as color and flexibility
• Recycled tires or plastic materials containing the above material(s)
• Lacquers, varnishes, or coatings such as plastic coatings made from synthetic polymers
Stakeholders should be aware that the guideline contains, inter alia, two important considerations:
• Rubber or plastic coatings on an article should be assessed separately for PAH content
• Tiles/mats used in public playgrounds and synthetic turfs used on artificial sports fields are for the general public and are under the scope of restriction
The publication of the guideline follows the publishing of Regulation (EU) 1272/2013 in December 2013, which came into effect in December 2015. This regulation expanded the scope of restriction on eight PAHs from tires to plastic and rubber materials in a wide variety of consumer products. In February 2017, the ECHA then asked for comments on the draft guidance document, which was then published in March 2018.
Stakeholders are advised to check their products are compliant with the latest requirements concerning PAHs under REACH.
SGS REACH Services
SGS keeps interested parties informed about developments and changes to REACH regulations. Their expertise, combined with consultancy services and experience in consumer product supply chains, provides a central point of contact for global solutions. Learn more about SGS’s REACH Services. [www.sgs.com/reach]
SGS SafeGuardS keep you up to date with the latest news and developments in the consumer goods industry. Read the full ECHA Publishes Guideline for PAHS under REACH SafeGuardS. [www.sgs.com/en/news/2018/04/safeguards-05318-echa-publishes-guideline-for-pahs-under-reach]
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For further information contact:
Hing Wo Tsang Ph.D
Global Information and Innovation Manager
Tel:(+852) 2774 7420
Email: crs.media ( @ ) sgs dot com
Website: www.sgs.com/cgnr
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