Chinese REACH: Restricted Substances Officially Released

Adherent (formerly Compliance & Risks). A panoramic view of the Shanghai skyline across a river, showing the Oriental Pearl TV Tower, Shanghai Tower, and other skyscrapers under a blue sky with clouds.

On 19 November 2020, the National Standardization Administration issued Announcement No. 26 of 2020, in which the “Chinese version of REACH restricted substances” -GB/T 39498-2020 “Guidelines for the Control of the Use of Key Chemical Substances in Consumer Products” is officially released. The standard will be implemented on 1 June 2021. Application scope This standard applies to consumer products, including product components, parts, accessories, packaging and instructions for use. But it does not apply to products under special government supervision such as food, medicine, cosmetics, tobacco, special equipment, aircraft, ships and military products. Main content This standard is prepared based on the EU “REACH Regulation ((EC) No 1907/2006)”. The limit requirements of this standard refer to the “EN71-9 General Requirements for Organic Compounds in Toys”, “EN71-12: 2013 Toy Safety-Part 12 N-nitrosamines and N-nitroso Compounds” and “Ecological textile standard Oeko-tex100-2017” and other foreign standards’ limit requirements. It puts forward restrictions on consumer products in China. That is to say, in accordance with the requirements of GB/T 39498-2020, it is necessary to focus on the control of the key chemical substances in consumer products, including heavy metals, alkanes, halogenated alkanes, benzenes, polycyclic aromatic hydrocarbons, phenols, aldehydes, ethers, alcohols, esters and salts, amines, dyes and other chemical substances that cannot be classified, etc. (117 categories in total). Recommendations for the control of key chemical substances in consumer products

Serial No.	Name	Cas No.	Control Recommendations	Applicable Scope in consumer products
1	Lead	7439-92-1 etc.	Lead content<0.05%	Any single part of a jewellery product
			Lead content≤90 mg/kg	a) All children’s paints and similar surface coatings b) Some furniture paints and similar surface coatings used by adults and children c) Household paints
			Lead content≤1000 mg/kg	Electronic and electrical products
			Migration of lead≤13.5 mg/kg	Dry, fragile, powdery or flexible toy materials
			Migration of lead≤3.4 mg/kg	Liquid or viscous toy materials
			Migration of lead≤160 mg/kg	Toy materials that can be scraped off
2	Mercury	7439-97-6 etc.	Migration of mercury≤7.5 mg/kg	Dry, fragile, powdery or flexible toy materials
			Migration of mercury≤7.5 mg/kg	Liquid or viscous toy materials
			Migration of mercury≤7.5 mg/kg	Toy materials that can be scraped off
			Disable	a) Clinical thermometer b) Other measuring instruments sold in public places

The issuance of this standard provides a basis for consumer product regulatory authorities to carry out quality or safety supervision for consumer products, provides safety technical requirements for consumer product-related companies in the design and manufacture of products, and provides technical reference for enterprises, governments and standard development institutions. Preparation background In recent years, recall notification of the European Union and the United States for consumer products in China showed that more than half of the product recalls occur due to the hazards of chemicals. The primary reason for this is that there is a lack of national standards regarding the restriction on chemical safety hazards in China. In order to accelerate the export of Chinese products and improve the products quality, it is urgent to compile standards on the control of key chemical substances in consumer products that meet the current industry standards and will lead the development of industry. In 2013, the China National Institute of Standardization together with over 10 scientific research institutions and enterprises applied to the National Standardization Administration for the establishment of the national standard project of the “Restriction Requirements for Chemical Hazards in Consumer Products” which was approved.

From July 2014 to December 2014, the drafting group completed the draft standard
From 28 March 2017 to 15April 2017, “Consumer Product Chemical Hazard Restriction Requirements” opens for public consultation
On 19 November 2020, the “Guidelines for the Control of the Use of Key Chemical Substances in Consumer Products” were officially released

Our recommendation Consumer products related companies should actively pay attention to the implementation of the standard and better understand the prohibited/restricted substances and related requirements. Meanwhile, related enterprises should fully respond to the standard by improving the products quality and reduce the overall risks of their products. Want to stay up-to-date on chemical regulations from across the globe? Sign up to our newsletter.