SGS Summarizes the new ECHA Q&A Document on Substance Restriction under REACH

The European Chemical Agency recently published a Question & Answer document on the implementation of Commission Regulation (EC) No 552/2009 (REACH Annex XVII) and its subsequent amendments on substance restrictions.
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Aug. 23, 2012 - PRLog -- In July, the European Chemical Agency (ECHA) has published a Q&A list on interpretation of several REACH substance restrictions. The document aims to provide guidance to both Member States and economic operators and will be complemented and updated if required by new amendments of Annex XVII. Below bullet points summarize the Q&A in a brief form:

Mercury in measuring devices (entry 18)
Question referring to: Repairing and maintenance activities
Exempted but shall not be used as this would be considered making available to the general public
Question referring to: Antique Barometers
•   Exempted

Arsenic compounds in wood (entry 19)
Question referring to: CCA treated wood
•   Prohibited to place on the market and to import wood newly treated with CCA until a biocidal product containing this active substance is authorized in line with all the requirements of Directive 98/8/EC (Biocide regulation)
•   Wood treated with CCA cannot be used for other applications than the ones listed in paragraph 4 b)

Cadmium and its compounds (entry 23)
Question referring to: Jewelry and imitation jewelry articles
•   Exempted if placed on the market for the first time before 10 December 2011

Nickel and its compounds (entry 27)
Question referring to: Mobile telephones
•   Applicable

CMR substances (entries 28 to 30)
Question referring to: Substances with concentration limits
•   Use the specific concentration limit as specified in Regulation (EC) No 1272/2008
•   If no relevant specific concentration limit is specified, use the relevant concentration specified in Directive 1999/45/EC

Flammable substances in aerosol generators for entertainment and decorative purposes (entry 40)
Question referring to: Colored hairsprays and glitter for the body
•   Exempted: covered by Directive 76/768/EEC for cosmetics

Nonylphenol (entry 46)
Question referring to: Traces in cosmetic products
•   Applicable

Toluene (entry 48)
Question referring to: Adhesive Tapes
•   Calculate with reference to the amount of adhesive on the tape, and not with reference to the total weight of the adhesive and substrate

Azodyes (entry 43)
Question referring to: Optical brightening agents (OBA)
•   To date, no OBA meet the definition of “azodye”

PAH in extender oils and tires (entry 50)
Question referring to: Interpretation of the term “major operational change”
•   Means any change in materials or processes that could invalidate the results of the proxy measurement
Question referring to: Tires for mobile machinery
•   Applicable for mobile machinery with a maximum design speed limit exceeding 25 km/h
Question referring to: Standard reference tires
•   Exempted

Phthalates in toys and childcare articles (entries 51 and 52)
Question referring to: Limit of 0.1%
•   Applicable to DEHP, DBP and BBP combined and applicable to DINP, DIDP and DNOP combined
Question referring to: Articles used for the hygiene of children
•   Applicable to articles such as bathtubs, articles for the bath, bathtub mats, hairbrushes, bath thermometers, or nail cutters
Question referring to: Mattress protectors
•   Applicable
Question referring to: Inclusion of Di-2-propyl heptyl phthalate (DPHP) in entry 52
•   Not included

Methylenediphenyl diisocyanate (MDI) (entry 56)
Question referring to: Definition of MDI
•   4,4’-Methylenediphenyl diisocyanate (EC Number 202-966-0; CAS Number 101-68-8), 2,4’-Methylenediphenyl diisocyanate (EC Number 227-534-9; CAS Number 5873-54-1) and 2,2’-Methylenediphenyl diisocyanate (EC Number 219-799-4; CAS Number 2536-05-2) are included
•   Dimers and polymeric forms of MDI are not included

Ammonium Nitrate (entry 58)
Question referring to: Concerned operators
•   Mixtures containing more than 16% of nitrogen in relation to ammonium nitrate may be placed on the market for supply to downstream users and distributors
•   Mixtures containing more than 16% of nitrogen in relation to ammonium nitrate shall not be placed on the market for supply to consumers

The SGS experts will follow up and inform interested parties as developments on REACH and other legislation occur. The SGS REACH expertise combined with consultancy services and experience in consumer product supply chains provides a central point of contact for global solutions.

If you would like to learn more about how SGS can support your REACH compliance activities, please contact:

Contact details:

SGS Consumer Testing Services

Jerome Vandenbroucke
REACH Technical Expert
Bât 8 - Parc du Golf
CS 30584
13 594 - Aix en Provence Cedex 3

t: +33 4 42 97 78 50

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