There are many items we use in our homes; such as furniture, clothing, vehicles, gadgets, books, toys and electronic gadgets. An object can be as simple as a wooden chair or as complex as a computer.
If you are not sure whether the product you send to the EU market is in the status of goods, you can use the following flow.
Article 3.3 of the REACH Regulation defines article as:
An object that has been given a special shape, surface or design during its manufacture that determines its function more than its chemical composition.
There are many items we use in our homes; such as furniture, clothing, vehicles, gadgets, books, toys and electronic gadgets. An object can be as simple as a wooden chair or as complex as a computer. If you are not sure whether the product you send to the EU market is in the status of goods, you can use the following flow.
(Click on the figure to view this diagram to help decide if your product is an item.)
Article suppliers must answer 3 key questions to establish their obligations under the REACH Regulation.
If there is an intended release and the amount of substance added to the article for this purpose is more than 1 ton/year per exporter
(For each raw material exceeding 1 ton/year if it is a preparation added to the article)
registration of the substance with the European Chemicals Agency (ECHA) is required.
(In this case, get information about your obligations such as Pre-registration / Registration / CLP Notification.)
If you do not have an intended release, continue to review the following questions.
Some chemicals have harmful effects that can cause cancer (carcinogen), cause genetic changes (mutagen), have a toxic effect on the reproduction of living things (reprotoxic), do not decompose in the environment for a long time (permanent pollutant), accumulate in the tissues of animals (bioaccumulate). These are substances of ‘high concern’ (SVHC). This category also includes chemicals that show an equivalent risk, such as ‘destroyers of the endocrine system’ in living things. One of the aims of REACH is to control such chemicals through the authorization procedure and to encourage industry to replace them with safer substances.
The use of such substances in articles is also tried to be controlled. ECHA publishes such chemicals as a Candidate List and aims to update this list at least every two years. Substances on this list will then go through the steps in the authorization procedure to enter Annex XIV of the REACH Regulation and be listed as Substances Subject to Authorization.
Firms supplying goods to the EU market have to determine whether they use these substances in the Candidate List by questioning their own suppliers (including the packaging of the products). Please call us for examples of letters in English and Turkish that you can use for such communications .
Industrialists who use more than 0.1% of a substance on the Candidate List in their products;
You can consult our expert for examples of calculating the ratio of the SVHC substance in the article. It is possible to follow the latest updates with our expert in line with the objections made by some countries such as Germany and France regarding the SVHC account in complex article. Does our article contain SVHC substance?.
Even if you are not currently using a substance on the candidate list in your production, do not forget that this list will be updated and should be followed. In order to take a step forward in this follow-up process, it is useful to check the lists published by some non-governmental organizations regarding SVHC substances. While these lists are not of an official nature, the items in them are likely to appear on the AKA’s candidate list in the future. We recommend that you take advantage of our consultancy services on this subject.
For the management of EU-wide risks that cannot be adequately controlled otherwise, a procedure has been introduced in which the manufacture, placing on the market or use of certain dangerous substances will be subject to certain conditions or prohibited. Restrictions are published as a list based not only on the substance name, but also on the usage area (condition). The restriction should be followed by article suppliers working for the EU market, as the restriction may also apply to the use of a substance in an article.
The REACH Regulation also inherits the restrictions previously applied in the EU.