Vol. 913 | 02 Jun 2016

As previously announced in Insight No. 826, from 1 June 2016, lead is restricted in consumer products supplied to the public in the EU under Entry 63 of Annex XVII of REACH. The total content limit of lead of 0.05% is applied to articles and accessible parts that can be mouthed by children (it is considered that an article or accessible part of an article may be placed in the mouth by children if it is smaller than 5 centimetres in one dimension or has a detachable or protruding part of that size).

The limit does not apply where it can be demonstrated that the rate of lead release does not exceed 0.05 μg/cm2 per hour (equivalent to 0.05 μg/g/h), and, for coated articles, that the coating is sufficient to ensure that this release rate is not exceeded for a period of at least two years of normal or reasonably foreseeable conditions of use of the article. However official methods are not currently available to determine lead release.

The requirements do not apply to articles within the scope of:

  1. Directive 94/62/EC (Packaging)
  2. Regulation (EC) No 1935/2004 (Materials and Articles in Contact with Food)
  3. Directive 2009/48/EC of the European Parliament and of the Council (Toys)
  4. Directive 2011/65/EU of the European Parliament and of the Council (Electrical items)

In addition the requirements do not apply to certain specific products such as keys and locks, the tips of writing instruments, musical instruments and crystal glass.

In May, the European Chemicals Agency (ECHA) published guidance on the scope of these lead restrictions.

It provides a flowchart to help decide if items are within the scope of the restriction and provides examples of articles that are within the scope on the basis they may be mouthed by children under normal or reasonably foreseeable conditions of use. These include clothing, footwear, sports and leisure items, stationery items, accessories, interior decorative items and childcare articles. It also gives examples of articles that are considered to be outside the scope of the restrictions such as fixed furnishings, fishing rods and weights, internal hinge mechanisms on frames, ski equipment and certain miniatures and models for adult collectors.

However all such decisions should be taken on a case-by-case basis. For example the handles on kitchen furniture may be outside the scope if they are on wall units but within scope if they are on drawer units within reach of a child.

For additional information please contact:

Philip Bullock
Technical Manager - Hardlines
+44(0)116 263 9606
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