fromECHA Helpdesk <helpdesk@echa.europa.eu>
to"plexconcil@vsnl.com" <plexconcil@vsnl.com>

dateTue, Aug 5, 2008 at 2:23 PM
subjectRE: [INC000000007548] Enquiry to ECHA - Chair bag (non EU)

Dear RAJAN KALYANPUR,

Thank you for your question related to the status of imported products (clothes) under REACH.

We assume Chairs, bags and comparable products may be considered as articles under REACH. REACH does not require registration of articles. However if a substance contained in the imported product is intended to be released, registration may be required in the conditions under Article 7(1) of REACH are met.

For determining whether or not a release may be intended please consult the rules and examples contained in the recently published Guidance on requirements for substances in articles, which you will find on the ECHA website: http://reach.jrc.it/docs/guidance_document/articles_en.htm.. Please refer to Section 6.1 and 6.2 (p40-47) of this guidance where borderline cases of intended release are described.

Although no registration is required, you may have notification and communication obligations if your articles contain substances that are on the Candidate List of Substances of Very High Concern for Authorisation.

An importer may have notification and communication obligations (see article 7(2) and Article 33) if the articles contains substances that are on the Candidate List of Substances of Very High Concern for Authorisation. These are substances that fulfil the criteria as laid down in Article 57 of REACH and may be subject to Authorisation. Such list will be published by ECHA for the first time late 2008 or early 2009.

• Notification of substances in articles is required when all conditions of Article 7(2) are met:
• The substance is included in the Candidate List of Substances of Very High Concern for Authorization (Article 59(1)) and
• The substance is present in all articles produced or imported by one actor in an amount totalling over 1 tonne per year (per producer or importer) and
• The substance is present in articles above a concentration of 0.1% weight by weight (w/w)

Please allow us to refer you to our website (http://echa.europa.eu/home_en.asp) that contains a wide range of information about REACH. We recommend you to consult the Guidance on requirements for substances in articles, which is available on the ECHA website: http://reach.jrc.it/docs/guidance_document/articles_en.htm .
 

We hope this answers your question. Should you have further questions you can contact us quoting the following reference number: 7548.

For new requests please do not forget to use the Information Request Form available at: http://echa.europa.eu/about/contact.asp .

Best regards,

ECHA Helpdesk

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Message topic: REACH Advice

Title: Mr.
First name: RAJAN
Last name: KALYANPUR
Country: India
Email address: plexconcil@vsnl.com

Organisation: THE PLASTICS EXPORT PROMOTION COUNCIL
Descr. organisation:
We are a non-profit organisation under the Department of Commerce, Government of India entrusted with the responsibility of promoting exports from the plastics sector. As such, we represent exporters from the Indian plastic industry and have a membership of over 2000 wh are engaged in the manufacture/export of plastic goods (including polmer manufacturers and plastic/polymer processors).

Organisation size: < 250 employees

Role under REACH: Other

Description of role "Other": Export Promotion Council (Trade Promotion Organisation)

Question:
Please let us know whether processed plastics are covered under REACH Legislation for registration. For example, a plastic chair made of Polypropylene; a plastic bag made out of HDPE. In short, any article made by processing a polymer o si this covered under REACH legislation and whether they will have to go through the process of pre-registration/registration.

Sent at: 04 / 07 / 2008 17:11 (EET, Helsinki)