The European Regulation Concerning the Registration, Evaluation, Authorization and Restriction of Chemicals

Pierre Thebault

Abstract: The European regulation n°1907/2006 of 18 December 2006 – commonly referred to as “REACH” – states the mandatory registration and evaluation of chemical substances marketed, manufactured or imported in quantities of more than one ton per year on the European market. This obligation not only applies to chemical substances but also to articles which contain chemical substances when they must be considered as associations of articles and chemical substances according to REACH, meaning that their chemical composition determines their function to a greater degree than or the same degree as the special shape, surface or design they are given during production.
In its “Guidance on requirements for substances in articles” (RIP 3.8), the European Chemical Agency (ECHA) mentions fireworks as examples of such associations of articles and chemical substances. The professional experts of CEN/TC 212 who developed the European standards for fireworks under a mandate of the European Commission disagree firmly with this statement. As a consequence they decided to react with their own arguments.
The present paper gives an overview of the arguments of the professional experts of CEN/TC 212, and recalls their previous attempt to promote them at the level of the European Commission and the opening they were given by return that might lead to possible specific action of the European Commission “including, in particular in the Guidance on requirements for substances in articles.” In that perspective and following the same approach that was adopted for ammunition by the European Defence Agency, they decided to prepare a professional guidance document in which they would express clearly their position in contradiction with ECHA’s position. Such document is intended to be presented to the European Commission in order to obtain its support and, consequently, a modification of ECHA’s position.
A task group was created by CEN/TC 212 to do so before the end of 2015.

Ref: JPyro, Issue 34, 2015, pp20-25 (J34-20)

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