Mapping of REACH (EC) No 1907/2006

The SAL comprises the following steps:

1. Substance Restrictions (Article 67) – Does the product contain substances whose use is restricted under Annex XVII?

2. Substances Intended to be Released (Article 7(1) and (6)) – Does the product contain substances that are intended to be released under normal or reasonably foreseeable conditions of use in quantities exceeding 1 tonne per year per manufacturer or importer?

The substance does not need to be registered by the article producer or importer if it has already been registered for that specific use (i.e. the use of the substance in the article) by another company.

3. SIA Notification (Article 7(2)) – Is notification to ECHA required for substances of very high concern (SVHCs) present above 0.1% w/w and exceeding 1 tonne per year?

4. Communication in the Supply Chain (Article 33) – Does the product contain SVHCs above 0.1% w/w that must be communicated within the supply chain?

5. Technical Documentation – Which records demonstrate compliance?

Examples include analytical test results or an established and documented Restricted Substances Control (RSC) system.

Note: SAL is not an end in itself. It provides a repeatable methodology that translates regulatory principles into a clear, structured assessment logic.

This diagram illustrates the SAL workflow visually:

Substance Restrictions (Article 67)

↓

Substances Intended to be Released (Registration)

↓

SIA Notification

↓

Communication in the Supply Chain

↓

Technical documentation

Interfaces to Related Legislation

When applying REACH, there are often interfaces with other regulatory frameworks that must be considered in parallel:

• Directive 2011/65/EU (RoHS)

• Waste Framework Directive 2008/98/EC – Article 9(1)(i) (SCIP notification)

• Other substance-related regulations (e.g. biocidal products, fluorinated greenhouse gases, ozone-depleting substances, persistent organic pollutants)

A coordinated assessment is therefore necessary to avoid regulatory gaps or duplicated evaluations. In practice, this means SAL provides the roadmap, but it must always be applied in the context of related legislation.

Overview: Regulation (EC) No 1907/2006 (REACH)

• Number: (EC) No 1907/2006

• Title: Regulation concerning the Registration, Evaluation, Authorisation and Restriction of Chemicals (REACH)

• Publication: OJ L 396, 30.12.2006, p. 1

• Purpose: Establishes provisions governing substances on their own, in mixtures, and in articles, including their manufacture, placing on the market, and use

• Public interest: Protection of human health and the environment

  
  

Guidance: Guidance on requirements for substances: Guidance for articles

Scope

In principle, REACH applies to all chemical substances, whether used in industrial processes or in everyday applications. This includes substances contained in articles such as clothing, furniture, and electrical equipment.

Within the context of this SAL, the focus is on obligations for producers and importers of articles, in particular with regard to substances contained in those articles.

Key Regulatory Requirements

Restrictions (Article 67)

Any substance on its own, in a mixture or in an article, may be subject to restrictions if its use poses an unacceptable risk to human health or the environment. These restrictions are listed in Annex XVII.

Substances Intended to be Released (Article 7(1) and (6))

A producer or importer of articles must submit a registration to ECHA for any substance contained in those articles if:

• the substance is present in quantities exceeding 1 tonne per year per producer or importer; and

• the substance is intended to be released under normal or reasonably foreseeable conditions of use.

Registration is not required if the substance has already been registered for that specific use by another company.

SIA Notification (Article 7(2))

Notification to ECHA is required if all of the following conditions are met:

• the substance is included in the Candidate List;

• the substance is present in the article above 0.1% w/w; and

• the total quantity exceeds 1 tonne per year per producer or importer.

Notification is not required if:

• exposure to humans or the environment can be excluded under normal or reasonably foreseeable conditions of use, including disposal (Article 7(3));

• the substance has already been registered for that use (Article 7(6)); or

• the articles were produced or imported before inclusion of the substance in the Candidate List (Article 7(7)).

Communication in the Supply Chain (Article 33)

Suppliers of articles containing SVHCs above 0.1% w/w must provide sufficient information to allow safe use of the article, including at least the name of the substance.

Additionally, suppliers must respond to consumer requests regarding the presence of SVHCs within 45 days.

Effective communication throughout the supply chain is essential to ensure safe use and regulatory transparency.

Conclusion

With SAL, the mapping as a roadmap, and consideration of interfaces to related legislation, it becomes clear how REACH Regulation (EC) No 1907/2006 is systematically applied. The resulting assessment logic provides a clear and practical roadmap from substance restrictions through registration and notification obligations to communication and documentation - ensuring transparent and robust compliance.