The EU has informed the WTO of its intention to expand the scope of restriction of PAHs under REACH. The new restrictions could become effective by mid-2022.

SAFEGUARDS | HardgoodsNO. 138/20

 SG 13820 Turf

On September 8, 2020, the World Trade Organization (WTO) announced a draft regulation from the European Union (EU) on its intention to expand the scope of restriction of the eight polycyclic aromatic hydrocarbons (PAHs) under entry 50 to Annex XVII of Regulation (EC) 1907/2006 ‘Registration, Evaluation, Authorization and Restriction of Chemicals (REACH).

The draft regulation and Annex, attached to WTO document number 20-6061, would restrict these eight PAHs when granules or mulches are used as an infill material in synthetic turf pitches, in loose form on playgrounds or in sport applications, such as golf courses, athletic arenas, horse arena footings, nature trails and shooting ranges. 

The origin of rubber granules and mulches is mainly end of life tires (ELT). The existing scope of restriction in entry 50 to Annex XVII of REACH does not regulate granules and mulches as these are classified as ‘mixtures’ under REACH.  

According to the definitions in the draft law, ‘granules’ and ‘mulches’ have the following meaning:

  • ‘Granules’ are mixtures that appear as solid particles, 1 to 4 mm in size and are made of rubber, other vulcanized or polymeric materials
  • ‘Mulches’ are mixtures that appear as flake-shaped solid particles, with a length of 4 to 130 mm and a width of 10 to 15 mm, and are made of rubber, other vulcanized or polymeric materials

The materials in granules and mulches can be from recycled or virgin materials, or they can be obtained from a natural source. 

The draft regulation is proposed to be adopted in Q1 of 2021 and the restrictions would become effective 12 months after the date of entry into force

Highlights of the draft regulation are summarized in Table 1.

WTO Document Number 20-6061, September 8, 2020
Draft regulation to amend Annex XVII of REACH as regards polycyclic aromatic hydrocarbons (PAHs) in granules or mulches used as infill material in synthetic turf pitches or in loose form on playgrounds or in sport application
Substance Scope Requirement Effective Date
8 PAHs:
BaP, BeP, BaA, CHR, BbFA, BjFA, BkFA and

Infill materials in:

  • Synthetic turf pitches
  • Loose form on playgrounds
  • Sport applications
≤ 20 mg/kg (sum of 8 PAHs) 
12 months after date of entry into force 
(potentially by mid-2022)
*BaP (Benzo[a]pyrene), BeP (Benzo[e]pyrene), BaA (Benzo[a]anthracene), CHR (Chrysene), BbFA (Benzo[b]fluoranthene, BjFA (Benzo[j]fluoranthene), BkFA (Benzo[k]fluoranthene) and DBAhA (Dibenzo[a,h]fluoranthene

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