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JCMA's commentary of REACH

Notice from JCMA

Important notice from The Japan Carbon Fiber Manufacturers Association (JCMA) with regard to the text published below.

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”.

- 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.