EU REACH can be a confusing regulation, even if you are just importing articles into the EU! At Toxnot, we've got you covered. When you indicate a particular item is an article, we will automatically apply the proper logic to ensure the article and the overall product its used in meet EU REACH.
What is an article?
An article is defined in the REACH regulation as "an object which during production is given a special shape, surface or design which determines its function to a greater degree than its chemical composition." This indicates that many components and parts that are purchased for use in your product are most likely unique articles.
An article can be thought of as finished products. For example, a plank of wood flooring, a sink, or a table would be a finished product, and therefore, an article under REACH. These finished products can also be made up of smaller components that are also considered to be articles. An example could be screws, a metal bar, or a faucet.
Have questions about whether your parts are articles? Reach out to email@example.com and we can provide you additional information and direction.
Why does a part being an article matter based on EU REACH regulation?
Both a part that is an article and the product as a whole must meet the requirements for EU REACH substances on their own. This means that all thresholds and other requirements need to be met by the individual part. Once any material, part, or component is marked as a REACH article, Toxnot automatically checks if the article meets EU REACH requirements.
I've determined that my part is or is not an article. How do I indicate that in Toxnot?
You can view the article status of a material, part, or component within the compliance view. In the image below, Toxnot asks if the part is a REACH article, which is where you can indicate or change the status of the part. This applies the article logic for the compliance roll-up on the individual part, as well as all the products the article is found in.
Toxnot System Settings for REACH Articles
Toxnot can also automatically classify linked materials as REACH articles, unless changed later during system use. We recommend this for most users that are not directly formulating products.
In the compliance library view (either Products or Materials), you can use the compliance options to automatically set imported materials as articles. Once you navigate to "Compliance Options," you can select "Default new Materials as REACH Articles." All products are automatically considered articles, so they do not need to be set to articles.
SCIP is the database for information on substances of concern in articles or in complex objects (products) established under the Waste Framework Directive.
Companies supplying articles containing substances of very high concern (SVHCs) on the Candidate List in a concentration above 0.1% weight by weight (w/w) on the EU market have to submit information on these articles to ECHA, as from 5 January 2021. The SCIP database ensures that the information on articles containing Candidate List substances is available throughout the whole lifecycle of products and materials, including at the waste stage. The information in the database is then made available to waste operators and consumers.
You can read more about Submitting Data to the SCIP Database.
Importing data about REACH Articles
Article status of a linked material can also be imported via the Summary Data Import. You can read more about that process in the Managing Summary Data article.
Reach out over chat or at firstname.lastname@example.org if you have questions.