JCMA regards, in the light of already firmly
established definition of “man-made fiber”, the carbon fiber and molded products made of carbon
fiber as illustrated below 1~4 shall be interpreted to be “Article” as defined in, and in
accordance with the given description in, REACH and also in “Guidance on Requirement for
Substances in Articles” as published by European Chemical Agency as of May, 2008.
1.Acrylic fiber (precursor), flame resistant fiber, and carbon fiber
- There is no
doubt that those fibers as above are “man-made fiber” and therefore shall be interpreted as
“Article”.
2.Short-cut fibers (including both of chopped fiber and middle-length fiber)
-
Either of those fibers retains a shape of fiber and is simply cut down into short-length only
for the purpose of letting them fulfill required physical performances. As their fabrics’ length
and diameter, but not chemical composition, has critical importance, Short-cut fibers shall be
interpreted as “Article”.
3.Prepreg
- Prepreg is a tight and uniform mixture of carbon fiber with various
types of resins molded into several shapes such as sheet, tape, or fibrous material by way of
mechanical processing such as cutting, laminate molding, winding etc. and because its shape,
surface characteristics, and appropriate design, not chemical composition, are overwhelmingly
and essentially important in fulfilling required performances, prepreg shall be interpreted as
“Article”.
4.Other carbon fiber products
- Carbon fiber itself and textile, blade,
non-woven sheet, carbon paper made of carbon fiber, and also heat-sealing material made of above
mentioned fabrics shall be interpreted to be “Article”.
- In addition to the above, composite products made of carbon fiber or the above
mentioned carbon fiber products shall also be interpreted to be “Article”.
- Contrary to
the above, in case an article needs to make “Intended release” or includes “Substance of very
high concern”, then it is definitely needed for an individual organization or a person to make
strict compliance with regulations contained in REACH. It must be stated, however, that even in
the case of releases of harmless oil or additives and also release of chemical compounds due to
inevitable chemical reactions taking place during usual usage, then that do not infringe the
definition of “Intended release”.
Important notice: The above are private view of JCMA reached by its interpretation of
REACH’s guidance relating to products made of or containing carbon fiber. Please be advised that
JCMA has not got any agreement or consent from authoritative agencies of EU such as European
Chemical Agency to those views of JCMA. In case anyone wants to make clearer the above
statement, please feel free to contact JCMA.
Those who want to further read the JCMA’s views, click below.
