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.
Examples of Borderline Cases Between Substances and Articles
The following cases are provided for enterprise reference:
Note that this catalog is for reference only. The official REACH text is the sole legally valid source. Users assume responsibility for how they use the information. Also, the catalog updates dynamically. ChemRadar will track and update it regularly.
The complete guide can be accessed via:
