Article Guide

Shape Over Substance

ePS Regulatory White Paper

Shape Over Substance

A practical guide to REACH articles

Determining what counts as an article under REACH — and what that classification actually obliges you to do.

Under REACH, whether an item is an article, a substance, or a mixture is decided by whether its shape determines its function more than its chemical composition does. That single distinction changes which obligations apply.

Get the classification wrong and you either carry registration duties you did not plan for, or miss notification and communication obligations you did not know you had.

What you will learn:

  • The shape-versus-composition test, applied to real product examples.
  • When a complex object is one article and when it is many.
  • SVHC notification and the 0.1% threshold — what it is calculated against.
  • Your Article 33 duty to communicate down the supply chain, and to consumers on request.

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