ECHA Releases Catalogue on Borderline Cases Between Articles and Substances/Mixtures

"On May 1, 2025, the European Chemicals Agency (ECHA) published the May 2025 edition of the Catalogue of Borderline Cases Between Articles and Substances/Mixtures. This document has been developed by the Borderline Working Group, established in March 2021 under the HelpNet Steering Group, with participation from REACH national helpdesks, Enforcement Forum members, and ECHA. The main objectives of the working group are to discuss complex queries received regarding borderline classification issues under REACH Article 3(3) and to compile a catalogue containing detailed case assessments of whether certain objects qualify as articles or substances/mixtures. The catalogue is designed to assist stakeholders in determining if an object meets the REACH definition of an article. It reflects the authors’ views and follows the guidance provided in Chapter 2 of the Guidance on Requirements for Substances in Articles. Each assessment is conducted on a case-by-case basis, and the conclusions are specific to the particular object evaluated. The document clarifies that similar objects may not always lead to the same conclusions and encourages comparison to identify common elements across cases. Where applicable, suggestions for similar cases are included in the 'Object' column of the overview. The catalogue comprises four key sections: 1.Introduction – Outlines the purpose and scope of the working group and the catalogue. 2.Overview of Agreed Borderline Cases – Lists examples of objects evaluated, including water-soluble plastic foil bags, foil bags with content (e.g. tablets), reusable cold or warm packs, single-use “instant” cold packs, heat patches or packs, car air fresheners, and silver/aluminium oxide catalysts. 3.Table of Detailed Assessment of Agreed Borderline Cases – Provides in-depth evaluations of the individual objects. 4.Appendix: List of Figure Sources – References sources used for visual documentation in the assessments."