Rank: New forum user 
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I have a client who recycles materials, for charity. One thing they recycle is old bicycle inner tubes and make them in to various things including laptop cases, wallets and they are looking at making a board game using some recycled materials including inner tubes.They have had the prototype game tested and the inner tubes contain higher than threshold limit for some chemicals in the rubber.Have they any obligations in REACH? Steve
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Rank: Super forum user
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In some cases the manufacture of recycled materials is the equivalent in risk or the original manufacture...additional registartion is NOT required where a substance or srticle was registered on its own in the EU....so long as it is exactly the same... The product testing should ensure that the use - or misuse is covered in the assessment of toxicological risk...which may be just as simple as review the technical dossier ...but for me the review must be by a BOHS qualified Industrial Hygienist..
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Rank: Super forum user 
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It is likely for rubber articles that the substances may include for example Short Chained Chlorinated Paraffins (SCCP) and Polycyclic Aromatic Hydrocarbons (PAH's) - these substances have market restrictions under REACH as not being permitted in products that may contact human skin. They really need a proper laboratory analysis to determine if contained substances appear on the REACH Annex XVII as restricted or Annex XIV as subject to authorisation.
https://echa.europa.eu/documents/10162/176064a8-0896-4124-87e1-75cdf2008d59
Once you move in to games then you have more arduous compliance against the articles of the Toy Safety Directive as well as just the substances contained.
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Rank: Super forum user
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It is likely for rubber articles that the substances may include for example Short Chained Chlorinated Paraffins (SCCP) and Polycyclic Aromatic Hydrocarbons (PAH's) - these substances have market restrictions under REACH as not being permitted in products that may contact human skin. They really need a proper laboratory analysis to determine if contained substances appear on the REACH Annex XVII as restricted or Annex XIV as subject to authorisation.
https://echa.europa.eu/documents/10162/176064a8-0896-4124-87e1-75cdf2008d59
Once you move in to games then you have more arduous compliance against the articles of the Toy Safety Directive as well as just the substances contained.
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