EU Seeks Comments for Draft Guideline on PAHs under REACH
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The EU is seeking comments for its draft guidance document on the restriction of PAHs in plastic and rubber materials in articles under Annex XVII of REACH.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  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  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The deadline for comments  on this draft guidance is April 19, 2017.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|
|1||Clothing, footwear, gloves and sportswear||
|2||Household utensils, trolleys and walking frames||
|4||Tools for domestic use||
|5||Watch-straps, wrist-bands, masks, head-bands and other similar articles||
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