The report on the REF-4 ECHA Enforcement project on restrictions was posted on the ECHA website[1].  The enforcement was conducted by inspectors in 27 European countries on 5,625 products, including 4,599 articles.  Overall, 18% of the products were found to not comply with substance restrictions.

The substances that were most frequently found in products above allowed thresholds were phthalates, cadmium, asbestos fibres, Polycyclic aromatic hydrocarbons (PAH), and hexavalent chromium.   Although EEE products were not specifically targeted in this enforcement project, the results indicate that there is still a significant non-compliance in the EU to substance restrictions and that authorities feel that additional actions need to be taken to reduce non-compliance

Recommendations arising from the project included:

• A need for more enforcement targeting high-risk areas;
• A need for companies to perform more due diligence in conformity assurance, especially analytical testing;
• Organize national and EU-wide campaigns to raise awareness of the restrictions

Increased awareness of the issues in the EU could lead to importers and distributors requesting more information from product manufacturers.

The report provided a series of recommendations to companies, including the following excerpt:

Companies placing chemicals or articles on the market that may contain substances restricted in REACH Annex XVII should pay a lot of attention to making sure that they know their products and their own suppliers. This may also need proactive testing of the products and agreements between suppliers to ensure that the chemical composition of the products in the supply chain is in accordance with the chemicals legislation.

[1] REACH Enforcement Project, https://echa.europa.eu/documents/10162/13577/ref_4_report_en.pdf/b53f5cd9-64a4-c120-1953-e9e176b9c282