The EU Directive 2017/1000 for REACH and Perfluorooctanoic Acid (PFOA) came into effect on July 4 this year. What is the status of products placed on the market for order prior to that date?

The EU Directive 2017/1000 is actually going to be removed because of an update to the EU POPs Recast Regulation. The start dates are the same as the Annex XVII restriction dates, but there are different exemptions and applicable begin dates, and some of the exemptions related to semiconductors have been removed. Once the EU POPs Recast is approved, the European Commission will make the applicable changes to the REACH Regulation.

The “placed on the market” language goes beyond the first time a product was ever placed on the market, and impacts products going into the EU after that date. For the PFOA restriction, that means all products in the EU before July 4, 2020, can have PFOA over threshold, and any products going into the EU after July 4, 2020, must have PFOAs below threshold.

Article is current as of 2020-07-10.

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