Background
In May 2025, the European Chemicals Agency (ECHA) released the fourth edition of the Catalogue of borderline cases between articles and substances/mixtures. This catalogue aims to assist enterprises in better understanding and applying the guidelines under the REACH Regulation regarding "substances in articles," clarifying whether a product falls under the scope of "articles" within the REACH regulatory framework. The catalogue compiles assessment conclusions from national regulatory authorities and ECHA on disputed cases, all of which originate from typical contentious scenarios encountered during actual regulatory consultations. These cases serve as critical references for enterprises to perform self-assessments.
