Question: I have an instruction manual that is associated with one of our products. Are the paper and ink in scope of REACH?
Answer: Nearly everything is in scope of EU REACH. That means the instruction manual would need to be evaluated for SVHCs over threshold and potentially any Annex XVII substances if the condition requires it be restricted.
The inks would be evaluated as a mixture, but the threshold would be considered at the article level. When doing the threshold calculation for the inks, you would examine the entire manual for SVHC(s) within the ink and complete the necessary reporting.
This information is accurate as of July 5, 2019.