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SAFEGUARDS | Consumer Products NO. 024/17

SafeGuardS The tools for tailoring clothes

The EU is seeking comments for its draft guideline relating to the restriction of nickel falling under Annex XVII of REACH. The deadline for comments is April 19, 2017.

The use of nickel and its compounds is governed by entry 27 to Annex XVII of REACH. Under this entry, there are three limits for the release of nickel in articles:

  • < 0.2 ug/cm²/week for post assemblies which are inserted into pierced ears and other pierced parts of the human body

  • ≤ 0.5 ug/cm²/week for articles intended to come into direct and prolonged contact with the skin such as earrings, necklaces, wrist-watch cases and rivet buttons

  • ≤ 0.5 ug/cm²/week for a period of at least two years of normal use for articles in the point above where these have a non-nickel coating

In April 2014, the European Chemicals Agency (ECHA) published a guideline [1] for the definition of ‘prolonged contact with the skin’ in the context of nickel restriction under Annex XVII of REACH. According to the guideline, ‘prolonged contact with the skin’ [2] is defined as contact with the skin of potentially more than either:

  • 10 minutes on three or more occasions within two weeks, or

  • 30 minutes on one or more occasions within two weeks

In January 2017, the ECHA published a draft guideline [3] to help the industry to comply with the scope of restriction for nickel under Annex XVII of REACH. According to the draft guideline, contact of more than 10 or 30 minutes needs to be continuous on each occasion. This draft guideline provides examples of articles and parts of articles considered to be within or outside the scope of restriction.

The draft guideline contains three Annexes. Annexes 1 and 3 are non-exhaustive lists of articles considered to be within the scope. Annex 1 includes articles already described in entry 27 to Annex XVII of REACH [4]. Annex 2 provides examples of products considered to be outside the scope of restriction. Annex 3 provides illustrative examples of articles considered to be within the scope of restriction.

It is interesting to note that external parts of mobile phones and similar types of article, such as tablets and pointing devices (trackballs, joysticks and touch pads), are also within the scope of restriction.

The deadline for comments [5] is April 19, 2017. The final guideline is envisaged to be published in the ECHA website to assist economic operators and enforcement authorities for compliance with nickel falling under entry 27 to Annex XVII of REACH.

Highlights of some articles or parts of articles which are expected to result in prolonged contact with the skin are indicated in Table 1.

Draft guideline on articles intended to come into direct and prolonged contact with the skin in relation to restriction entry 27 of Annex XVII to REACH on: Nickel and nickel compounds
January 23, 2017, ECHA
Entry Article or part of article Example of articles or parts of articles which are in prolonged contact with the skin (except for those already mentioned)
1 Grips
  • Bikes and kick scooters
  • Garden and gym tools and equipment
  • Scissors and umbrellas
2 Hand-held equipment and devices

Outer cases or holding areas: Calculators, cameras, curlers, electric razors, flashlights and hair dryers

Holding area: Fishing and hunting equipment

3 Handles
  • Garden and home equipment
  • Golf clubs, prams and shower heads
4 Rudders, wheels and gear sticks
  • Boats and ships
  • Cars and other vehicles
5 Seats/backs/arm-rests Chairs or similar furniture
6 Tools and utensils used by hand

Articles: Manicure/pedicure tools, needles, pencil sharpeners and pins

Holding areas:

  • Combs, mugs and writing instruments
  • Tools such as pocket knives and pliers

Outer cases: Cosmetic and powder containers, pencil cases and similar pocket articles

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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