Know Your Products

Some examples of complex products affected by REACH:

Polymers

Although polymers are exempt from registration, actual monomers and starting materials need to be pre-registered and registered according to specific guidelines. This applies even if the polymer is manufactured outside the EU and the reactants are consumed in the process. However, exposure-based waiving rules can sometimes apply to reduce registration data requirements.

Components in polymer systems are usually within the scope of registration as substances in 'preparations'. Stabilizers and solvents necessary for the stability of imported polymers are currently exempt from registration because they are considered part of the polymer substance itself. However any excess amount of these above that required for the stability of the polymer must be considered as subject to registration.

Polymers face authorization and restriction. Monomers are not considered as intermediates for registration, but are for the purpose of exemptions from Authorization. Other reactants in polymers may benefit from reduced intermediate registration requirements, but only if strict control conditions can be demonstrated (including in the actual polymer). Complex rules apply to natural polymers if they are subject to any chemical modification.

Cosmetics

The ingredients of cosmetics are subject to registration and the packaging around them is subject to communication requirements.  Any occupational and environmental exposure must be considered in a registration dossier, certain data points relating to consumer protection can be excluded.  Preservatives in cosmetics are subject to REACH even of covered by EU Biocides Directive.

Recovered Materials

Recovered and recycled materials are exempt from registration if the component substances have already been registered.  Pre-registration of materials is however necessary to benefit from the exemption.

Finished Products

A specific set of requirements applies to certain types of 'articles' (i.e. finished materials, containers and packaging).  This includes the need to communicate Candidate List substances present at above 0.1% w/w.

Many products containing substances must be managed separately as 'preparations' and 'articles'.  For instance, a pen is considered as an article (delivery system) containing a preparation (ink).  The substances in the ink must therefore be pre-registered, either at point of manufacture or import.  The other parts of the pen must meet the article requirements for communication through supply chain.  Similarly, the substances in the cleaning wipe are considered as part of a preparation.  The wipe material is considered separately as an article (delivery system).