物品指的是生产过程中给予了特殊的形状、表面或设计的物体,很大程度上决定于其功能而不是化学组成。
因此“当一个物品被组装成更复杂的物品时,它便不再是一个物品”缺乏理论依据
参考ECHA的Guidance on requirements for substances in articles(February 2017,Draft Version4.0)
When determining if and which REACH substance in articles requirements apply to a given object which is produced, imported and/or placed on the EU market, the first step is to check whether or not the object is considered as an article under REACH. Objects may be simple, like a paper sheet, but can also be very complex, like a laptop computer, consisting of many articles.
Article 3(3) of the REACH Regulation defines an article as “an object which during production is given a special shape, surface or design which determines its function to a greater degree than its chemical composition.
An article is an object composed of one or more substances or mixtures which were given a specific shape, surface or design during the production process. It may be produced from natural materials, such as wood or wool, or from synthetic ones, such as polyethylene (PE). Most of the commonly used objects in private households and industries are themselves articles, or contain articles, e.g. furniture, clothes, vehicles, books, toys, kitchen equipment and electronic equipment.
In order to determine whether or not an object fulfils the definition of an article under REACH, the object’s function and its shape, surface or design need to be assessed.
Articles that are assembled or joined together remain articles, as long as they keep a special shape, surface or design, which is more decisive for their function than their chemical composition, or as long as they do not become waste.