REACH for Article Manufacturers

Only substances have to be registered, preparations or articles do not. An article is "an object, which during production is given a special shape, surface, or design that determines its function to a greater degree than does its chemical composition."  Manufacturers of articles have more limited requirements under REACH.

Manufacturers of articles within the EU will need to ensure that the substances and preparations they use in manufacturing have been registered for their particular uses.  In addition they will need to follow all proscribed control measures communicated from their suppliers via safety data sheets.

Manufacturers of articles (in the EU) and importers of articles (into the EU) also will need to ensure that the substances in their articles are registered if:

  • Greater than one ton per year is intended to be released under normal or reasonably foreseeable conditions of use ; or
  • They contain  greater than 0.1% concentration of substances of very high concern (SVHCs)

Manufacturers of articles containing candidate SVHCs also have notification and downstream user communication requirements.

A Candidate List of 1,500 SVHCs [CMRs (carcinogenic, mutagenic, or toxic to reproduction), PBTs (persistent, bioaccumulative, and toxic), vPvBs (very persistent and very bioaccumulative), and endocrine disruptors] is expected to be published in the summer 08, on the ECHA website

We recommend the following resources as a starting point:

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