Meaning of an Article in the Context of REACH
According to REACH Regulation (EC) No. 1907/2006, any supplier of an "article" containing a Substance of Very High Concern (SVHC) from the Candidate List at a concentration above 0.1% weight by weight must communicate this information to the recipient of the article. Additionally, the revised Waste Framework Directive (2008/98/EC) requires that such articles be notified to the SCIP database.
Agricultural machinery consists of complex objects made up of thousands of articles joined together in various ways (e.g., mechanically, welded, etc.). Due to the high complexity of these products, determining the concentration of SVHCs within them can lead to different interpretations, particularly when legal texts or ECHA guidance do not provide sufficient clarification.
It is important to determine whether an individual "article" retains its status as an article when assembled into a larger object or if it becomes part of a "new article." This distinction affects the calculation of SVHC concentrations and, consequently, the reporting obligations to both ECHA and the recipients of the complex object.
To support agricultural machinery manufacturers in their assessments, CEMA has prepared guidance on the definition of an "article" within the REACH framework. This document provides clarification on how to calculate the concentration of candidate list substances relative to the weight of a complex object.
Find the document below.
