The REACH working group, which was mandated by CEN to produce guidance on the application of REACH to pyrotechnic articles in general, and fireworks in particular, has prepared the attached draft guide.
Click here: CEN TC 212 Professionnal REACH Guidance Fireworks V5
The working group will shortly approach both the REACH authorities and the European Commission and present this guide – which concludes that in almost all cases fireworks should be considered as articles under REACH and not as containers for substances (the exception being sublimed dye containing smoke generators).
The onus on determining whether an article falls within scope of REACH rests with the importer of the product (obviously true manufacturers may be importing raw chemicals in quantities subject to the REACH requirements) but may be subject to challenge by the enforcing authorities. This guide provides a pan-European rationale behind the conclusion that most fireworks are ARTICLES under REACH (despite ECHA’s own guidance) and has been endorsed by many European Associations as well as by BAM (The German authority akin to HSE).