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The European Chemicals Agency (ECHA) has published a guidance document in relation to the restriction of polycyclic aromatic hydrocarbons (PAHs) under entry 50 to Annex XVII of REACH. This document provides general considerations on the scope and examples of products or components falling or not falling under the scope of restriction.

SAFEGUARDS | Consumer Products NO. 053/18

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In December 2013, the EU published Regulation (EU) 1272/2013 expanding the scope of restriction of eight PAHs 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 expanded scope [1] has been effective since December 2015. 

In February 2017, we had informed you [2] that the ECHA had announced a call for comments for the draft guidance document in relation to the restriction of PAHs in plastic and rubber materials in articles that are supplied to the general public under Annex XVII of REACH. The deadline for comments for that draft guideline was April 2017.

The ECHA has made available the guideline dated March 7, 2018 [3] to assist the consumer products industry to comply with the scope of restriction on PAHs under entry 50 to Annex XVII of REACH.  This (non-legal binding) 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 are considered to be within or outside the scope of restriction. Annex 3 of the guideline also provides thirteen illustrative examples of articles or components in articles that are considered to be within the scope of restriction.

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
  • Recycled tires or plastic materials containing the above material(s)
  • Lacquers, varnishes, or coatings such as plastic coatings made from synthetic polymers

The guideline contains, inter alia, two important considerations. These are the following:

  • Rubber or plastic coatings on an article should be assessed separately for PAH content
  • Tiles/mats used in public playgrounds and synthetic turfs used on artificial sports fields are for the general public and are under the scope of restriction 

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

Highlights of some articles, or components/materials in articles, which are made of plastic/rubber and may be in direct as well as prolonged or short-term repetitive contact with the skin or oral cavity, that are considered to be within the scope of restriction are summarized in Table 1.

Guideline on the scope of restriction entry 50 of Annex XVII to REACH: Polycyclic aromatic hydrocarbons in articles supplied to the general public, March 7, 2018
Item
Product
Example
1
Clothing, footwear, gloves and sportswear
  • Corsets, gloves, hats, shoes for babies, socks and underwear
  • Footwear (apart from underside)
  • Rucksacks/backpacks (handles, belts, buckles at the belts and plastic parts for adjustment of the straps as well as areas in contact with back and shoulders)
2
Household utensils, trolleys and walking frames
  • Handles and wrist straps in crutches and walking sticks
  • Handles and holding areas in cookware and cooking utensils, domestic appliances and tool
  • Holding and drinking areas in plastic mugs and thermos bottles
  • Mats and table cloths & mobile and portable devices
  • Outside and accessible inside of hand and shoulder bags
3
Sports equipment
  • Carpet piles (turf filaments) and elements that become accessible after wear during normal use in synthetic turf carpets for artificial sports fields
  • Frisbees, gym/stretching balls, shuttlecocks and yoga/stretching mats
  • Grips, seats and handlebars in bicycles and kick scooters
  • Handles in dumb-bell sets, golf clubs, paddles and racquets
  • Inside parts of canoes, kayaks and similar light boats
4
Toys and childcare articles
  • Bath toys, changing pads, children’s bikes, cots/cribs, mattresses, plastic or rubber figurines, pillows, plastic swords, rubber balloons, run bikes, teethers, toy scooters and toy mowers.
  • Outer areas and accessible inside of baby walkers, dolls, guns, high chairs, musical instruments and painting articles
5
Watch-straps, wrists-bands, masks, head bands and similar articles
  • Combs/brushes, eye cups, headbands, sunglasses, tooth brushes, watch-straps, whistles and wrists-bands
  • Handles in umbrellas
  • Outer areas in earplugs, mobile audio devices and protective equipment
6
Miscellaneous
  • Back rests, handles, legs, seats and table tops in furniture for public places
  • Caps and holding areas (apart from tips) in writing instruments
  • Carpet piles (turf filaments) and elements that become accessible after wear during
    normal/reasonable use
  • Erasers, eyelash curlers, manicures, rubber bands, and textiles and fibers for making clothing
  • Vehicles (gear sticks, grips, seat belts, steering wheels and upholstery of seats)

Next step:

Stakeholders are advised to comply with the latest requirements for PAHs in consumer products for the EU market.

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 Information and Innovation Manager
t: +852 2774 7420

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