
Layman's report
Enabling REACH consumer information rights on chemicals in articles by IT-tools


About LIFE AskREACH
The project was co-funded and supported by the European Environment programme LIFE, German Federal Environmental Foundation (DBU - Deutsche Bundesstiftung Umwelt), State Regional Development Agency Republic of Latvia (VRAA).
The overall goal of LIFE AskREACH was to enhance the substitution of Substances of Very High Concern (SVHCs)* in articles* by increasing the market demand for SVHC-free articles and supporting industrial actors to identify SVHC in their articles. The digital products developed during the project - the Scan4Chem mobile app and the AskREACH database - facilitated and promoted Business to Consumer communication.

When IT engineers meet chemical policy needs
The EU REACH Regulation on the Registration, Evaluation, Authorization and Restriction of Chemicals (1907/2006/EU) came into effect in 2007. Its aim is to ensure a high level of protection for human health and the environment, as well as the free circulation of chemical substances on the internal market and the enhancement of competitiveness and innovation.
Article 33 of REACH states that a manufacturer or seller is obliged, on request, to inform a consumer if a given article contains SVHCs. This obligation applies as soon as at least one SVHC is present at a concentration of more than 0.1% by weight in that article. The information must be made available within 45 days and must include at least the name of the SVHC substance.
Article 33 applies to most solid objects such as clothing, furniture, toys, or electronics offered for consumer use. In the case of food, medicines and “non-solid” articles such as cosmetics, cleaning agents, paints, or powders, the obligation to provide information applies only to the packaging.
People are becoming increasingly aware that they have the right to ask about SVHCs in articles on the European market. SVHC information is not considered confidential and should be disclosed to consumers on request.
The LIFE AskREACH project has invested considerable efforts in developing and promoting IT tools to facilitate communication about SVHCs along the supply chain and between suppliers and consumers. Informed purchasing decisions by consumers should provide market incentives to develop and use safer alternatives to SVHCs. This approach is also in line with EU policy regarding chemical traceability - to provide clear and understandable information about chemical substances to citizens, workers, and businesses in all languages of the EU, as well as the need to increase transparency and traceability throughout the supply chain.
In our view, these digital solutions are well suited to facilitate communications and extend the reach of SVHC information at both Business to consumer and Business to business levels. Let’s find out more about the AskREACH IT tools!
AskReach Database
The AskREACH database for article suppliers* is one of main project results. When a company registers in the database and enters their article data, information is automatically passed on to every consumer that checks one of the company articles via the app. For articles without information in the database, an e-mail request is sent to the supplier each time a consumer asks for the information. SVHC information management goes through the supplier front end.
Contacting companies using Scan4Chem!
The project developed a smartphone application that allows consumers to send a ‘right to know’ request after scanning a product’s barcode, relying on the awareness of the article suppliers about their “duty to tell” and respond to requests from consumers. That’s why the Scan4Chem app helps consumers to find out whether an article contains SVHCs at concentrations above 0.1 % by scanning article barcodes and/or sending requests to companies. Some consumers got confused why a supplier doesn’t reply to information request, but according to Art.33 no response is required if there is no SVHC at above 0.1% w/w in the product. Also, the answer should be sent within 45 days which is a rather long period.
Scan4Chem allows European consumers to easily request product information from suppliers about the presence of SVHCs. The free-of-charge app is for checking SVHCs in products like clothing, sports equipment, toys, etc. Scan4Chem is available in 20 countries: Austria, Bulgaria, Croatia, Czech Republic, Denmark (Tjek Kemien), Estonia, France, Germany, Sweden (Kemikalieappen), Greece, Latvia, Lithuania, Luxembourg, Poland (Pytaj o Chemię), Portugal, Serbia, Hungary, Bosnia-Herzegovina, and Spain. In early 2022, the ToxFox app was connected to the AskREACH database, offering similar features as Scan4Chem.
How did we involve companies?
Raise awareness and strengthen your consumer power
It is said that consumers vote with their wallets. That’s exactly right - by buying certain products, we stimulate demand for them, showing that society needs these things. Consumers are powerful drivers who “vote” for goods, products, and services every day through their choices. In order to make informed decisions, it is important for the society to know about SVHCs, which can seem quite complex at first sight. Hazardous chemicals in products are not an everyday topic for the majority of the public, so the challenge for the AskREACH project was to transmit information about SVHCs and the importance of this topic. The main objectives of the consumer campaign were to raise awareness about SVHCs, their effects on human health and the environment, to inform about alternative choices and to promote the Scan4Chem app.
What can we conclude and what’s next?
What has AskREACH achieved?
Chemicals management and SVHCs are challenging topics which will always be in competition with societal processes and other environmental challenges. The LIFE AskREACH project drew attention to the problems of SVHCs in articles and a ‘right to know’ by bringing together a diverse array of stakeholders and engaging all sides in fruitful discussions revolving around, but not limited to, the implementation of REACH Art. 33. It provided valuable insights towards better policy development and implementation, supporting the information flow about chemicals between industry, suppliers, and consumers.
Responsibilities
When it comes to awareness and choice, it would be unfair to put all the responsibility on consumers - after all, it is the companies that produce and deliver the goods, and largely within the framework of existing regulations.
Insight from project expert Dr. Susana Fonseca at the AskREACH final conference:
Given the immense investments into awareness raising campaigns, AskREACH is a stunning example how mere information provision to the consumers does not automatically lead to behavioural change. Politicians need to understand that consumers can never be the sole engine of the transition to SVHC free products. Rather, it is crucial to emphasize the responsibility of industry and address this with the right instruments and policies.
What’s next?
At the AskREACH final conference, deputy-project manager Heidrun Fammler underlined that
Making Art. 33 work is a tremendous communication task. Having spent major project budget for staff, we can say: It is people that make Art. 33 work.
There is still a huge amount of work to be done to raise awareness and levels of understanding among both companies and the consumers. Human health and environmental quality are among the most important issues, so the topic of SVHC’s and chemrical management must be taken seriously. Upcoming EU policy initiatives such as eco-design egulation and a digital product passport (DPP) will extend the need for communications and information exchange about SVHCs in articles and support traceability throughout the lifecycle of products.