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The European Chemicals Agency (ECHA) is seeking comments on a draft guidance document, published in January 2017, on the restriction of polycyclic aromatic hydrocarbons (PAHs) in plastic and rubber materials. The draft guidelines assist stakeholders in complying with restrictions enforced under entry 50 in Annex XVII of REACH.

The guidelines relate to an expansion in the scope of PAH restrictions introduced, via Regulation (EU) 1272/2013, in December 2013. The amendment became effective in December 2015 and saw an enlargement in the extent of the restrictions, which now go beyond covering just tires to include plastic and rubber materials used in:

  • Toys
  • Childcare articles
  • Articles for the general public, for example:

o Clothing, footwear, gloves and sportswear

o Household utensils, trolleys and walking frames

o Sports equipment

o Tools for domestic use

o Watch-straps, wrist-bands, masks, head-bands and other similar articles

o Miscellaneous articles, including:

- Erasers

- Carpet piles in artificial grass

- Holding areas in writing instruments

- Manicure/pedicure tools such as nail files

- Outer casings in cigarette lighters

- Pocket articles such as cosmetic or powder containers

- Tiles and mats used in playgrounds and sports fields

- Grips, upholstery of seats, seat belts, gear sticks and steering wheels in vehicles such as cars, scooters and boats

The restrictions apply if the materials, under normal or foreseeable conditions of use, come into direct contact with human skin or the oral cavity in a prolonged or short-term manner. The December 2013 amendment introduced two sets of limits: one for articles used by the general public and a more stringent set of limits for toys and childcare items.

The draft guideline published by the ECHA in January 2017 also contains a non-exhaustive list of articles and subtypes that are considered to be within or outside the scope of the restriction. In addition, the guidelines present a ‘stepwise approach’ for stakeholders to use in identifying whether an article falls within the scope of the restrictions.

The guidelines state that PAHs may be found in:

  • Mineral oils and coal-based extender/plasticizer oils, as a natural contaminant, that are used in the manufacture of rubber and plastic materials
  • Carbon black (soot) that is intentionally added to elastomers to give certain characteristics such as color and flexibility
  • Lacquers, varnishes or coatings

Stakeholders have until April 19, 2017, to make representation to the ECHA on the draft guidance. Following this, a final guideline will be published on the ECHA website to assist economic operators and enforcement authorities with compliance for PAH restrictions falling under Annex XVII of REACH.

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For further information contact:

Hing Wo Tsang

Global Hardlines Information and Innovation Manager

Tel:(+852) 2774 7420



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