Question: How is an "article" defined under REACH, especially in the case of component products that are assembled and imported into the EU as finished goods? I've heard of "once an article, always an article" - what does that mean, and how does it affect my declaration responsibilities?
Answer: The definition of an article from the REACH regulation is "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".
Prior to 2015, it was commonly understood that a complex article made up of multiple parts was considered a single article. However, a 2015 ruling by the European Court of Justice established the "Once An Article, Always An Article" definition. This means that if a product or component part ever meets the above definition of "article," it will continue to be considered an article even if it is later assembled into a larger product. For instance, ABS molded parts or the dielectric in a capacitor would likely be considered articles, and would each need to comply with REACH.
If any article contains a SVHC over the 0.1 percent w/w threshold, the supplier (and each purchaser) has supply-chain communication requirements. For more information on these requirements, see REACH SVHC Communication & Reporting Requirements.
Complex Objects refer to objects made up of more than one article. In complex objects, several articles can be joined or assembled together. The more articles it is made of, the more complex an object becomes. An example of a complex object is a thermometer, which comprises more than one article and contains a substance/mixture as an integral part.
Furthermore, a very complex object refers to combinations of simpler complex objects plus further articles, such as multi-socket power strips, sofas, bicycles, mobile phones, computers, video cameras, cars, and aircraft.
Figure 1: Types of complex objects
For more information on defining articles under REACH, download a copy of Assent's whitepaper REACH: Applying the New Article Interpretation.
Article valid as of Oct. 24, 2019