ECHA Publishes REACH Regulations PAHs Guidelines

On March 7, 2018, ECHA issued guidelines to help the consumer goods industry comply with the scope of control of Article 50 PAHs in Appendix XVII to REACH Regulations. The (non-legally binding) guide provides a "step-by-step approach" to assess whether an item is within the limits and lists incomplete lists of items and subcategories within and outside the limits. At the same time, 13 examples of items or components within the limits are listed in Annex 3.

According to the guidelines, polycyclic aromatic hydrocarbons may exist in the following materials:

1. As a natural pollutant, it exists in mineral oil, coal-based filler oil and plasticizer oil used to produce rubber and plastics.

2. Carbon black (soot) intentionally added to elastic rubber to give color and elasticity to the rubber;

3. Recycled tires or plastic materials containing the above materials;

4. Paints, varnishes or coatings, such as plastic coatings made from synthetic polymers.

In particular, two important considerations are included in the guide, as follows:

1. PAH content in rubber or plastic coatings should be assessed separately.

2. Ceramic tiles/mats used in public places and artificial turf used in artificial playgrounds are used by the public and are included in the scope of restrictions.

Annexes 1 and 3 list items or components within limits, with illustrative examples in Annex 3. Annex 2 lists examples of consumer goods that should be considered outside the limits.

Table 1 briefly summarizes examples of items or components that should be considered to be within limits, made of plastics or rubber, and which have direct, long-term or short-term repetitive contact with skin or mouth.