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Valpak Limited - Is Your Business REACH Compliant?

Ashleigh Williams
Mar 01, 2016

Is your business REACH compliant? 5 unexpected products that are affected

For me the word “chemicals” conjures up images of products such as bleach, washing powder and hair dye, which is why I think that a number of businesses who are affected by the REACH Regulations still do not realise that they are obligated.

Many may not be aware that the scope of the Registration, Evaluation, Authorisation and Restriction of Chemicals (REACH) Regulations is far reaching and the proverbial net is cast wide to capture a range of different products. The regulations not only affect chemical substances but also products (articles) that release chemicals during use as well as those which contain chemicals, such as electrical items or clothing. This is a real concern, as obligated businesses that are not currently compliant could face fines, or other enforcement action such as the receipt of improvement notices, for not meeting the requirements of these regulations.

It is understandable why a business might assume that certain products do not fall within scope of the regulations, because they are not chemical substances or do not release chemicals. However, some unusual suspects such as clothing, electrical items, home furnishings, toys and many other types of products are affected.

Unusual suspects

With this in mind I have put together a shortlist of five unexpected products that obligate a business under the REACH regulations:

    1. T-shirt
      T-shirts do not release chemicals, so they are classed as articles of no-release under REACH. However, t-shirts may contain substances of very high concern (SVHCs), which means that if a business handles t-shirts or other items of clothing it may be affected by REACH
    2. Electronic tablet
      An electronic tablet is another product that does not release chemicals; however, these products may still contain substances of very high concern (SVHCs). This means that if a business handles tablets or other electronic products it may be affected by REACH. Electronic items often contain a number of components; therefore, assessing the components against applicable SVHC thresholds may prove to be challenging for some businesses
    3. Scented candle
      A scented candle is classed as an article of release (a product that releases chemicals) under REACH, due to its added function of releasing scent when lit. The quantities of substances within scented candles have to be assessed to determine applicable obligations
    4. Ink cartridge
      An ink cartridge contains a combination of substances; therefore, the obligations of these products and the substances/ mixtures contained within them will need to be considered
    5. Fireworks
      Fireworks contain a combination of substances; therefore, the obligations of fireworks and the substances/ mixtures contained within them will need to be considered

Who is obligated?

I also wish to point out that it’s not only manufacturers of these products that will have an obligation under REACH. Many types of businesses could be affected, from importers to end users, which is why it is important to find out if your business is obligated.

Next steps

If you think that your business could be affected by REACH, Valpak can help. We are running a series of drop in sessions at our head office in Stratford-upon-Avon, so please do book a place if you require further clarification or peace of mind.

Alternatively, please give us a call on 03450 682 572 to discuss your business operations and your products. We will be able to provide advice and assistance, and help you to ensure that you’re compliant if we discover you are obligated.



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Disclaimer: The opinions expressed in this weblog represent those of the individual authors and not those of Valpak Limited or any other organisation.