When you create a product, you can specify the product category. Until now, you had the choice between Mixture and Substance. Now, you also have the option Article. There are many dangerous substances (from lead to cadmium, nickel, or phthalates) which are found in common consumer products (like toys, jewelry, or yoga mats) and when those products are found to be non-compliant with current regulations, those products must be pulled from the market at significant costs.
The REACH Regulation defines an article as “an object which during production is given a special shape, surface or design which determines its function to a greater degree than its chemical composition”.
A core principle of the Classification, Labelling and Packaging Regulation is the 'self-classification' of a substance or mixture (and now article) by the manufacturer, importer or downstream user.
Under some circumstances, article importers have to register or notify substances in articles to ECHA (see Article 7 of REACH): these obligations are in general the same as for producers of articles. When placing articles on the market in the EEA, importers of articles may also have to communicate information on substances in their articles to their customers.
This self-classification aims to determine whether a chemical substance or mixture has physical, health and/or environmental hazards and to properly communicate these hazards with appropriate labelling in the supply chain when the product is placed on the market, regardless of the volume of the substance or mixture produced. Now we can integrate this information into product marketability, to ensure compliance for transporting and sales of such products.
The specified product categorization is maintained and displayed in the Manage Basic Compliance Data - Unpackaged Products or Manage Basic Compliance Data - Raw Materials app.
When we create a new unpackaged product or raw material, Article is now an option under Product Categorization.
When we edit an existing unpackaged product or raw material, Article is now an option there as well.
We can see product categorization status in the header when looking at the basic compliance data.
Previously, the categorization was done in the Manage Analytical Composition app.
If a different product categorization is required for a specific legal area, the product categorization can be overwritten as a part of the legal-area-specific analytical composition.
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