EU REACH Regulation Tightens Lead Restrictions

The European Union (EU) has expanded the scope of restriction of lead to articles or accessible parts of articles for the general public if children can place such articles or components in the mouth. The enforcement date will be June 1, 2016.

Amendments to EU REACH to Protect Young Children

In October 2014 information was released that the European Commission (EC) had notified the World Trade Organization (WTO) of a proposal (http://newsletter.sgs.com/eNewsletterPro/uploadedimages/000006/sgs-safeguards-17814-eu-notifies-wto-draft-regulation-restriction-lead-reach-a4-en-14.pdf) to amend the restriction of lead under ANNEX XVII of REACH.

On April 23, 2015, Regulation (EU) 2015/628 (http://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=OJ:JOL_2015_104_R_0003&from=EN) was published in the Official Journal of the European Union (OJEU) to expand the scope of lead restriction from jewelry articles to articles or accessible parts of articles for the general public if children can place such products or components in the mouth during normal or reasonably foreseeable use.  An article or an accessible part of article can be placed in the mouth by children if it is less than 5 cm (< 5 cm) in one dimension or has a detachable or protruding part of that size.

Regulations Not Limited to Lead in Jewelry and Toys

The new law places a restriction of no more than 0.05% lead content in the new scope of products or components. It also provides a number of exemptions, including a migration limit of 0.05 microgram/cm² per hour (equivalent to 0.05 microgram/g/h) as an alternative to the lead content limit.

According to the new legislation, guidelines identifying products that are inside and outside the scope of the regulation should be developed to assist economic operators and enforcement authorities. 

Highlights of the existing Regulation (EU) 836/2012 and the new regulation are summarized in a table within the latest SGS SafeGuards bulletin (http://newsletter.sgs.com/eNewsletterPro/uploadedimages/000006/sgs-safeguards-06915-eu-expands-lead-restriction-under-reach-a4-en-15.pdf).

Exemptions

Regulation (EU) 2015/628 also exempts the following:

- Articles placed on the market for the first time before June 1, 2016

- Articles or parts of articles comprising alloys provided the brass alloy is no more than 0.5% lead

- Jewelry under Regulation (EU) 836/2012

- Keys and locks, including padlocks

- Musical instruments

- Portable zinc-carbon batteries and button cells

- Religious articles

- Tips of writing instruments

- Articles within the scope of

   * Packaging Directive 94/62/EC

   * Food Contact Regulation (EC) 1935/2004

   * Toy Safety Directive 2009/48/EC

   * RoHs Recast Directive 2011/65/EU

About SGS Testing and Safety of Consumer Products

Throughout its global network of laboratories, SGS is able to provide a range of services, including analytical testing and consultancy, for lead and restricted substances in consumer products (http://www.sgs.com/cgnr) for the EU and international markets.

Please do not hesitate to contact an SGS expert for further information.

Contact details:

SGS Consumer Testing Services

HingWo Tsang
Global Toys and Juvenile Products Information and Innovation Manager
SGS Hong Kong Limited
1/F On Wui Centre
25 Lok Yip Road
Fanling, N.T., Hong Kong, China

t: +852 2774 7420
Email: [email protected]   
Website: www.sgs.com/reach

SGS is the world’s leading inspection, verification, testing and certification company. SGS is recognized as the global benchmark for quality and integrity. With more than 80,000 employees, SGS operates a network of over 1,650 offices and laboratories around the world.