Scope of REACH Annex XVII Extended in Compliance Data Exchange System
Annex XVII of REACH places restrictions on the manufacture, marketing, and use of chemicals where it is deemed they pose an unacceptable risk to human health or the environment. Restrictions can take the form of a blanket ban such as Entry 6 banning the manufacture and use of asbestos fibres (with an exemption for the use of diaphragms containing chrysotile for electrolysis installations that are exempted by a Member State). Restrictions may extend to the supply of chemicals to the general public on their own or in mixtures, but not to professional users of those chemicals where the risks of their use can be better controlled. And finally restrictions can be sector and use specific such as Entry 51 which bans the use of certain phthalate plasticizers in toys and childcare articles.
Annex XVII is therefore of direct relevant to companies using Compliance Data Exchange (CDX) to support compliance with chemicals regulation (www.cdxsystem.com is the sister system of IMDS, catering for industries beyond automotive). Companies using CDX can analyse received data from suppliers using the Where Used function to find parts and materials that contain substances on Annex XVII. If an Annex XVII substance is found, Users can then use the Regulation Overview function to look up the detail of the restrictions applicable to any substances found.
During the April updates to the CDX Basic Substance list, EPR worked with DXC Technology to extend the scope of Annex XVII to incorporate more restrictions that are applicable to consumer uses of chemicals and mixtures. The scope now covers the following Annex XVII Entries:
1; 2; 4; 5; 6; 7; 8; 12; 13; 14; 15; 16; 17; 18; 19; 20; 21; 22; 23; 24; 25; 26; 27; 28; 29; 30; 31; 32; 34; 35; 36; 37; 38; 41; 43; 45; 46; 46a; 47; 48; 49; 50; 51; 52; 54; 55; 56; 59; 60; 61; 62; 63; and 64.
This scope extension is in recognition of the fact that companies using CDX have broad product portfolio’s and they need to capture restrictions applicable to professional and industrial uses of chemicals, but also any restrictions that may apply to chemicals or mixtures supplied to the general public.