Article (REACH definition)

The REACH Regulation makes a fundamental distinction between substances, mixtures and articles – this classification determines the respective duties that apply to manufacturers, importers and suppliers. For articles, Category 33 (duty to communicate information on SVHCs > 0.1%) and Category 7(2) (duty to notify the ECHA) are particularly relevant.

For complex products assembled from multiple components, the principle "Once an article – always an article" applies: the 0.1% threshold for SVHCs is applied to each individual article, not to the assembled product as a whole. This interpretation is based on the ruling of the European Court of Justice (ECJ, Case C-106/14) and has far-reaching consequences for supply chain communication and product documentation.

In operational practice, companies systematically document the article status of their products, link material data with SVHC assessments and prepare structured information packages for industrial as well as commercial users and consumers. Crucial interfaces exist with the SCIP database (Substances of Concern In articles as such or in complex objects - Products), PLM (Product Lifecycle Management) systems, procurement processes and quality management systems.

For importers and producers of articles, distinguishing these from substances and mixtures is critical: whilst substances and mixtures are subject to registration duties under Article 6, articles are primarily subject to information and notification requirements. Correct classification also dictates the applicability of restrictions (Annex XVII) and authorisation requirements (Annex XIV).