In response to the request of the European Commission, European Chemicals Agency (ECHA) calls for comments about the draft guidance1of polycyclic aromatic hydrocarbons (PAH) in consumer products. This draft guidance clarified the scope of PAH restriction, entry 50 of REACH Annex XVII2, based on the materials and conditions of use. This also equipped with examples to illustrate the interpretation. Stakeholders are welcome to comment and the consultation3 will end on 19 April 2017.
Back in 2013, we reported in the E-essential newsletter volume 784 about the amendment of PAH restriction. Regulation (EU) No 1272/2013 amending REACH Annex XVII, entry 50 restricts PAH in consumer products. The scope of restriction is applicable to articles supplied to the general public and made of rubber and plastic materials with direct prolonged or short-term repetitive skin contact. Further guidance on determining the scope was to be developed. ECHA was requested by the European Commission in late 2014 to develop a practical guideline with indicative examples about the scope of the restriction.
The draft guidance listed the criteria to determine whether the articles or its parts are within the scope of restriction. It also described the possible materials that may contain PAH. For example, rubber and plastic of which mineral oils or carbon black is used during the production process, lacquers/varnishes, or coatings (e.g. plastic coating made of synthetic organic polymers). Another topic that attracts most concern is how to define whether the articles or its parts is of “prolonged” or “short-term repetitive”. However, not enough scientific evidence is available for the PAH migration from articles to the dosage received by human after a certain period of contact time. The guidance advised that the articles or parts that within minimal skin contact are considered as out of the scope of restriction. For example, the inaccessible or internal components, components that are only accessed during simple maintenance or upgrading work, articles or components in short and infrequent contact with the skin or oral cavity. A non-exhaustive list of examples that are within or out of the scope can be found in Annexes 1 to 3.