However, in July 2013, six nations issued a guidance document on an alternative definition of an “article”. The six nations involved comprise of five members of the European Union (Belgium, Germany, France, Denmark, Sweden) plus Norway. These nations take the view of “once an article, always an article” and they take the stance that a product is made from other articles which, have been bought by the manufacturer at some time in the past.

In contrast, the ECHA guidance regards the limit of 0.1%w/w for a selling unit as a complete article.

If we take a bag as an example, the complete article approach taken by the ECHA and by most other EU-nations is that the 0.1%w/w limit would apply to the entire bag, as a whole product. However, the view of the dissenting states is that the 0.1%w/w limit would apply separately to all articles within that bag; for example, outer, lining, zip, buckle etc. The reason for this is that there is a possibility that lightweight components which, could potentially have high levels of SVHCs are then “masked” by the combined weight of the end product.

REACH can be a complex piece of legislation to comprehend, especially when all is not harmonious between EU member states. BLC Leather Technology Centre can keep you posted as to how this situation develops. For more information on REACH regulations, please contact