New ECHA Guidance Document

April 1, 2011, the European Chemicals Agency has released the second version of the “guidance on requirements for substances in articles”.

Companies manufacturing, importing or dealing with articles should follow the interpretations of this guidance document. Although they are not legally binding, the guidance documents are used by national authorities and serve as consultation sources in court proceedings.

An important change within the guidance document may, in a worst case, lead to new obligations for those producers or importers of products that are not longer seen as articles but as substances.

Suddenly, those companies may find themselves under the obligation to register. In such a case it might well be that they have not done a pre-registration or have even missed a deadline already.

Check now, whether your product is, in the light of the new guidance document, rather viewed as an article or as a substance or preparation, and re-assess your obligations under REACH.