The REACH Scope

EU REACH – Registration, Evaluation, Authorization, and Restriction of Chemicals – is a comprehensive regulation enacted by the European Union to manage and ensure the safe use of chemicals. The REACH scope covers hundreds of substances, including those used in industrial processes, consumer products, and within the environment.

Product under the REACH Scope

First, the EU REACH scope covers:

Chemical substances. They are substances on their own (pure form) or those contained in mixtures or articles.
Manufacturers. Any company or individual producing chemicals within the European Union must comply with REACH requirements.
Importers. REACH also applies to substances imported into the EU, regardless of whether they are produced within the EU or imported from outside.
Downstream users. Users of chemicals in industrial processes, professional activities, or consumer products must comply with certain obligations under REACH, such as safe use and communication of information along the supply chain.
Articles. Finally, REACH covers substances in articles (also called products), such as electronics, textiles, packaging, tools, furniture, or objects of any shape.

REACH Scope of Products

In sort, virtually any products fall under the RoHS Scope, with a few exemptions.

Out-of-Scope Products

Here are some of the few products that are out of the REACH scope:

Oil products
Food
Radioactive products
Drugs and medicine

Why are these products out of the REACH scope? Because distinct regulations apply to them.

Examples of Articles under the EU REACH Scope

Other than those listed above, any new article in the EU market falls under REACH. Under the EU REACH scope, “articles” refer to finished products or objects made of one or more substances with a specific shape, surface, or design that determines their function to a greater degree than the chemical composition. Examples of articles include:

Electrical and electronic equipment (EEE). Devices such as smartphones, laptops, televisions, and household appliances. They also include professional and industrial EEE.
Textiles and apparel. Clothing, footwear, textiles, and accessories.
Furniture. Chairs, tables, sofas, beds, cabinets, and other furnishings.
Toys. Playthings for children, including games, dolls, action figures, and building blocks.
Automobiles and automotive parts. Vehicles, vehicle components, and accessories.
Construction materials. Building materials such as bricks, cement, insulation, and piping.
Packaging materials. Containers, boxes, bags, and packaging for transportation and storage.
Jewelry and accessories. Ornaments, watches, bracelets, rings, and other personal adornments.
Sports equipment. Equipment used for various sports activities, including balls, bats, rackets, and protective gear.
Medical devices. Instruments, apparatus, appliances, and implants used for medical purposes.
Household products. Items used for cleaning, hygiene, gardening, and other household activities.
Stationery and office supplies. Pens, pencils, markers, paper, notebooks, and office equipment.
Musical instruments. Instances are guitars, pianos, drums, and brass or woodwind instruments.
Cookware and kitchen utensils. Pots, pans, knives, cutlery, and kitchen appliances.
Art and craft supplies. Materials used for artistic and creative activities, including paints, brushes, clay, and canvases.

Two Categories of Articles

The examples above illustrate the diverse range of products that fall under the scope of articles as defined by the EU REACH regulation. We can categorize them into two types of articles:

The articles that contain substance(s) intended to be released. These substances leave the product under normal conditions of use. As a result, some chemicals eventually end up in the environment while using the article. Examples are ink cartridges, pesticide applicators, shaving foam sprays, etc. Other emissions than chemicals, like heat, are not considered here.
The articles, in general, that are without substances intended to be released. They are the most common type of articles. Batteries, most electrical and electronic equipment, and packaging fall into this category.

What are the Article Producer's Obligations?

Manufacturers, importers, and distributors of articles have certain obligations under REACH, including communicating information about substances of very high concern (SVHCs) present in articles and ensuring compliance with restrictions or authorization requirements for hazardous substances.

In short, any SVHC above the threshold of 0.1% must appear on a public database called the SCIP database. This obligation applies at the component level, not the finished product. Additionally, there is no minimum quantity or product weight for this obligation to apply.

What is REACH about?

Overall, the scope of EU REACH is broad, aiming to ensure the safe handling and use of chemicals throughout their lifecycle, from production to disposal, to protect human health and the environment within the European Union.

On top of the obligations to article producers discussed above, here’s an overview of the aspects and scope of EU REACH:

Registration: REACH requires manufacturers, importers, and downstream users of chemicals to register them with the European Chemicals Agency (ECHA). This obligation applies to substances produced or imported in one tonne or more annually. The registration requires detailed information about the chemical’s properties, uses, and safe handling.
Evaluation: ECHA evaluates the information submitted during the registration process to ensure compliance with the regulation. It may also involve the identification of SVHC based on their hazardous properties or potential impact on human health or the environment.
Authorization. Certain substances identified as SVHC may require ECHA to authorize their use. It is granted only upon demonstrating that adequate control of the risks associated with the substance exists or if there are no available suitable alternatives.
Restriction: REACH empowers the European Commission to impose restrictions on the manufacture, placing on the market, or use of certain substances regarded as risky to human health or the environment.

If you are unsure about the REACH scope and need an external opinion or need to REACH test your products, contact Enviropass!