ECHA Publishes Guideline for PAHS under REACH
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
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  has been effective since December 2015.
In February 2017, we had informed you  that the ECHA had announced a call for comments for the draft guidance document in relation to the restriction of PAHs in plastic and rubber materials in articles that are supplied to the general public under Annex XVII of REACH.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  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|
||Clothing, footwear, gloves and sportswear
||Household utensils, trolleys and walking frames
||Toys and childcare articles
||Watch-straps, wrists-bands, masks, head bands and similar articles
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
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