ECHA Releases New Draft Guidance on Requirements for Substances in Articles

ECHA Releases New Draft Guidance on Requirements for Substances in Articles

The European Chemicals Agency has released a new draft guidance document aimed at assisting stakeholders in fulfilling their obligations under the Registration, Evaluation, Authorisation and Restriction of Chemicals (REACH) Regulation. The draft guidance elaborates on the judgement of the European Court of Justice on 10 September, 2015, with respect to complex articles, or the notion of ‘once an article, always an article’.

Broadly, the Court’s 2015 judgement clarified the scope of the notification and communication obligations under REACH. After this clarification, the ECHA published an updated guidance document (Version 3.0) in December 2015 to modify key components of the document that were no longer accurate in the wake of the judgement.

The February 2017 Guidance just published in draft format (Version 4.0) offers an even more comprehensive update and includes a range of new examples that are more consistent with the Court’s decision regarding the new article interpretation.


To learn more about what constitutes an article under REACH, click here to download the whitepaper REACH: Applying the New Article Interpretation.


Specifically, the new guidance helps companies decide whether they need to fulfill the registration (Article 7(1)), communication (Article 33) and/or notification (Article 7(2)) requirements related to substances in articles. This document will therefore be most relevant for personnel responsible for REACH compliance within companies doing business in the EU, representatives of non-EU companies producing and exporting articles to the EU, and experts from industry associations or other stakeholder organizations tasked with informing companies about REACH requirements and updates.

You can access the ECHA’s draft Guidance here.

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