The sub-study on substances in articles of the project „Advancing REACH“ analyses, under the perspective of the aims of the REACH Regulation and the requirements formulated in the context of the “circular economy package”, the current legal framework of instruments governing the risk management and related notification and communication obligations concerning “substances in articles” (SiA). The study discusses the definition of the term “article” and its interplay with chemical substances contained in the article or that are an integral element thereof. The subsequent sections analyse the communication obligations in the professional supply chain and towards consumers, the provisions on the registration and notification of SiA as well as the authorisation and restriction schemes.
Each section assesses the respective legal framework (objectives, mechanisms, uncertainties) as well as the state of the art regarding implementation and, based on lessons learned, develops policy options to enhance the framework. Tables at the end of each section summarize the options and the expected effects.
Whilst an in-depth impact analysis of the presented options is beyond the scope of the study, the findings suggest the need to clarify the legal context. This is true for each of the problem areas analysed.