Following a request of the European Commission (EC), European Chemicals Agency (ECHA) prepared a draft guideline1 of nickel release restriction, entry 27 of REACH Annex XVII, and calls for comments from stakeholders from 25 January 2017. This draft guideline aims to help the producers, importers, distributors and the Member States' authorities to understand and comply with the nickel release restriction under REACH Annex XVII. The consultation2 will end on 19 April 2017.
The nickel release restriction targets the post assemblies and the articles intended to come into direct and prolonged contact with the skin. The restriction does not define the term "prolonged contact with the skin". In 2014, ECHA published an interpretation3, and the term is defined as contact with the skin of nickel of potentially more than
10 minutes on three or more occasions within two weeks, or
30 minutes on one or more occasions within two weeks.
As a follow up action, the EC requested ECHA to prepare a guideline and insert examples of articles that could be within or outside the scope of the restriction.
This draft guideline interpreted the scope of "articles intended to come into direct and prolonged contact with the skin". ECHA suggest to consider both normal use and reasonably foreseeable conditions of use. The draft guideline also further clarified the interpretation of "prolonged contact with the skin". It states that the contact of more than 10 or 30 minutes need to be continuous and not consisting of several discontinuous periods of contacts. The Annexes 1 to 3 provide a non-exhaustive list of examples of articles types and subtypes that are within or outside the scope of the nickel restriction.