NO.CLE/ED/REACH/2012
Jan. 2, 2013

Members of the Council

Sub ; Proposed restriction on presence of polycyclic aromatic hydrocarbons (PAHs) in articles supplied to the general public under REACH regulation

Dear Member

Members are aware that REACH is the European Union Chemical Regulation (EC) N°1907/2006 governing the Registration, Evaluation, Aurthorization and Restrictions of Chemicals. of the European Parliament and the Council dated 18 December 2006. The Regulation Directive came into force on 1st June 2007, to streamline and coalease various regulations on chemicals of the European Union (EU). REACH is a dynamic regulation that places onus on industry to manage the risks that chemicals may pose to the health and the environment.

Depending on whether the product belongs to category of substance ( pure chemical), mixture preparation (mixture of chemicals), Article (whose shape determines its use as leather bags, garments, furniture etc), different obligations apply. As leather goods as shoes, bags jackets belong to category of article, only obligations related to article apply.

Members are also aware that the Council has engaged M/s SGS India Pvt. Ltd., as one of the official agencies for providing REACH related services to members. We have now received an update from SGS concerning REACH

The European Commission has notified the World Trade Organization of its intention to add a restriction to REACH covering the presence of the following polycyclic aromatic hydrocarbons (PAHs) in articles supplied to the general public.

• benzo[a]pyrene
• benzo[e]pyrene
• benzo[a]anthracene
• chrysene
• benzo[b]fluoranthene
• benzo[j]fluoranthene
• benzo[k]fluoranthene
• dibenzo[a,h]anthracene.

The proposed restriction targets articles that come into direct and prolonged contact with the human skin or the oral cavity. The restriction, if adopted by the EU, will be the first example of the so-called “fast track” restriction procedure outlined in Article 68.2 of REACH which can be applied to carcinogenic, mutagenic and reprotoxic substances coming into contact with consumers. The restriction proposals lists articles including toys, sports equipment, household utensils, tools for domestic use, clothing, and watch straps.

If the above restriction on PAHs is enforced by listing them under Annex XVII of REACH, the allowed limits of such PAHs will be 1 mg/kg ( 0.001% by weight of this component) of any of the listed PAHs.

The vote of REACH Comitology Committee on the restriction proposal is expected in January 2013 after the WTO consultation has ended. Then the proposal will pass to the European Parliament and Council according to the comitology procedure. The restriction could be adopted in the second half of 2013.

The detailed information material received from SGS India is enclosed for reference of members. This is for kind information of members.

With regards

R. Ramesh Kumar I.A.S
Executive Director
COUNCIL FOR LEATHER EXPORTS

Proposed restriction on presence of polycyclic aromatic hydrocarbons (PAHs) in Consumer Articles