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