EU REACH - Definition of Articles in Assembled Products

Question:

Is REACH compliance required for component parts that are in a final assembled product imported into the EU as finished goods? An example being an ABS moulded part, a painted steel part and electronic components.


Answer:

EU REACH applies to all articles within a product which often includes sub-products of a larger product under the clarification applied by the European Court of Justice ruling. The ruling is also known as Once An Article, Always An Article (OA5) indicating that if anything within a product is considered an article, it must be included when calculating the product SVHC communication requirements.

Article definition: ‘an object which during production is given a special shape, surface or design which determines its function to a greater degree than does its chemical composition’.

Using the definition, all of the components mentioned above would likely be considered articles and the threshold for SVHCs of 0.1% w/w of the article would need to be calculated to determine if communication to customers and notification to ECHA is required.

Reference: https://curia.europa.eu/jcms/jcms/P_173743/fr/

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