German NGO provides a gateway for REACH article 33 enquiries

In cooperation with the German Federal Environment Agency (Umweltbundesamt, UBA) the NGO BUND (federation for environment and nature conservation) has setup an online gateway for enquiries regarding REACH article 33. Consumers can request for information about products by indication of the EAN code and suggests that the product have already been bought.

REACH Article 33.2 says that, on their request, consumers have to be informed about so called candidate substances in articles > 0,1 mass% within 45 days and cost-free. This obligation applies whether the product has been bought already or not and can also be used as purchase decision.

Whilst the websites of the UBA do contain all relevant information about the information that can be requested and on which types of products the requirements apply, the information provided by the BUND may be misleading for people who are not familiar with the REACH regulation and may raise false expectations.

The BUND says: „Within 45 days the supplier of the product has to inform you which chemicals are contained in the product.“

Besides the fact, that „chemical“ does not mean a dangerous or toxic substance in general, only information about substances of the candidate list that are contained in concentrations > 0,1 mass% have to be indicated. As the current list contains 73 substances and is slowly growing, there are still many substances that are not subject to information requirements.

In addition, it is not clear, if UBA and BUND expect to receive information according to the dissenting opinion from German authorities who say: once an article, always an article.