EU Seeks Comments for Draft Guideline on PAHs under REACH

February 6, 2017

SAFEGUARDS | Consumer Products NO. 021/17

The EU is seeking comments for its draft guidance document on the restriction of PAHs in plastic and rubber materials in articles under Annex XVII of REACH. The deadline for comments is April 19, 2017.

In December 2013, the EU published Regulation (EU) 1272/2013 expanding the scope of restriction of polycyclic aromatic hydrocarbons (PAHs) falling under entry 50 to Annex XVII of REACH. The scope was expanded [1] from tires to plastic and rubber materials in toys, childcare articles and articles for the general public if these materials come into direct as well as prolonged or short-term repetitive contact with the human skin or the oral cavity under normal and foreseeable conditions of use. This amendment introduced two sets of limits: one for articles for the general public and a more stringent set of limits for toys and childcare articles. It also indicated that a guideline should be developed to assist the industry to comply with the new law. This amendment has been effective since December 2015.

In January 2017, the European Chemicals Agency (ECHA) published a draft guideline [2] to assist the industry to comply with the scope of restriction of PAHs under Annex XVII of REACH. This draft guideline provides a ‘stepwise approach’ to assess whether an article would fall within the scope of restriction and contains non-exhaustive lists of articles and subtypes that is considered to be within or outside the scope of restriction. Certain articles that are considered to be within the scope of restriction are also illustrated in Annex 3.

According to the guideline, PAHs may be present in the following materials:

As a natural contaminant in mineral oils and coal-based extender/plasticizer oils that are used in the manufacture of rubber and plastic materials
Carbon black (soot) that is intentionally added to elastomers to give certain characteristics such as color and flexibility
Lacquers, varnishes or coatings

The deadline for comments [3] on this draft guidance is April 19, 2017. The final guideline is expected to be published in the ECHA website to assist economic operators and enforcement authorities for compliance with PAHs falling under Annex XVII of REACH.

The full list of examples of articles that are considered to fall under the scope can be found in Annexes 1 and 3. Annex 2 provides examples of products that are considered to be outside the scope of the restriction.

Highlights of some articles that are considered to be within the scope are summarized in Table 1.

Draft guideline on the scope of restriction of PAHs in plastic and rubber materials in articles supplied to the general public if these materials come into direct as well as prolonged or short-term repetitive contact with the human skin or the oral cavity under normal and foreseeable conditions of use January 23, 2017, ECHA
Entry	Product	Example
1	Clothing, footwear, gloves and sportswear	Footwear such as sandals and shoes other than soles Gloves, hats and underwear Print on T-shirts and other clothing Rucksacks/backpacks Wet suits
2	Household utensils, trolleys and walking frames	Computer mouses and mouse pads Handles and holding areas in cookware and cooking utensils Holding areas and buttons in handheld game consoles Holding areas in thermos bottles and plastic mugs Seats, handles, back rests and table tops in furniture Tablecloths and mats
3	Sports equipment	Frisbees, golf bags and shuttlecocks Handles and grip areas in hand-operated air pumps Horns, grips and seats in bicycles and kick scooters Inside parts of kayaks, canoes and similar light boats
4	Tools for domestic use	Handles or grip areas in tools, gardening tools, electrical tools and scissors
5	Watch-straps, wrist-bands, masks, head-bands and other similar articles	Handles, plastic cases and buttons in musical instruments Pulse monitors and sunglasses Straps, cuffs and bulbs in domestic blood-pressure meters Watch-straps, wrists-bands and activity trackers
6	Miscellaneous articles	Erasers Carpet piles in artificial grass Holding areas in writing instruments Manicure/pedicure tools such as nail files Outer casings in cigarette lighters Pocket articles such as cosmetic or powder containers Tiles and mats used in playgrounds and sports fields Grips, upholstery of seats, seat belts, gear sticks and steering wheels in vehicles such as cars, scooters and boats

SGS will follow up and inform interested parties as developments on REACH regulation occur. Our 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 visit www.sgs.com/reach

For enquiries, please contact:

Hingwo Tsang
Global Hardlines Information and Innovation Manager
t: +852 2774 7420

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