Pens, glues, crayons, erasers, pencil cases, scissors and school bags are all examples of back-to-school products. European retailers and their suppliers may be familiar with their obligations for ‘articles’ under REACH, but may not be too familiar with procedures for ‘mixtures.’
In the European Union (EU), Regulation (EC) No. 1907/2006 (REACH) (http://www.reach.sgs.com/documents/cts_regulation_ec_n_1907_2006.pdf) governs substances on their own, in mixtures and contained within articles. In the context of consumer products, the general obligation to register substances on their own and in mixtures is when their annual production volumes or imported quantities are one metric ton or more per EU manufacturer or EU importer per year. Other obligations include supplying safety data sheets (SDS) and to apply for notification under classification, labeling and packaging of chemical substances and mixtures (CLP) if hazardous substances are present. For articles, the general obligations are to observe the restricted substances limits and if applicable, communicate information on Substances of Very High Concern (SVHC) and submit an SVHC notification.
Pen inks, glues, correction fluids, crayons and water color paints are classified as ’mixtures’ under REACH. Scented articles, such as erasers, are classified as articles containing substances intended to be released, where the erasers are articles and the scented substances are intended to be released.
Manufactures and importers of back-to-school products for articles such as rulers, pencil cases and school bags have to observe another set of obligations as well as registration and safety data sheets. They are obliged to communicate the name of the SVHC (http://www.ee.sgs.com/svhc.htm) present in a product and information on the safe use of the product along the supply chain in accordance with Article 33 of REACH.
SGS has a dedicated team to offer REACH services (www.reach.sgs.com) including the preparation of dossiers for registration, safety data sheets and SVHC analysis.
For further information on our REACH services, please contact:
Contact details:
SGS Consumer Testing Services Hing Wo Tsang Senior Technical Manager, Chemical Laboratory – Hardlines
SGS Hong Kong Ltd., 5-8/F & 28/F, Metropole Square 2 On Yiu Street, Siu Lek Yuen Shatin, 999077, N.T. Hong Kong
t: +852 277 474 20
E-mail: cts.media@sgs.com Website: www.reach.sgs.com
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