Wednesday, January 7, 2015

REACH Annex XVII - Restricted Substance List

The Annex XVII of REACH regulation contains the list of restrictions of certain hazardous substances, mixtures and articles for their marketing and use on the European market. A restriction can apply to any substance on its own, in a mixture or in an article, including those that do not require registration.

REACH Annex XVII includes all the restrictions adopted in the framework of REACH and the previous legislation, Directive 76/769/EEC. Each entry shows the substance or group of substances or the mixture, and the consequent restrictions conditions.

Reminder: There are 3 important regulatory lists under REACH: REACH SVHC ListREACH Authorization List and REACH Restricted Substance List. Have you read about the other two lists?

Current State of REACH Restricted Substance List

Currently there are 64 entries on Annex XVII (updated in Jan 2015). Each entry restricts the use of one substance or one group of substances. The example below shows how entry 50 restricts the use of a group of Polycyclic-aromatic hydrocarbons(PAH) in tyres and extender oils.
REACH Restriction PAH Example

Impact of REACH Restricted Substance List

Since REACH restriction list covers a big number of substances, it is impossible to identify if your product contains any substance on the restriction list by testing all substances. Instead you shall read all 64 entries and identify which entry is relevant to your product first. It only takes about half an hour to read all 64 entries.

If you have identified one entry that is relevant to your product, then you can conduct further testing to check if your product meets restriction conditions set by that specific entry or not.

It shall be noted that you also need to check if your products contain any Substances of Very High Concern (SVHC) and comply with relevant requirements.
More info

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