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Paragraph 1 of entry 23 of Annex XVII to the REACH Regulation provides a restriction on cadmium and its compounds in mixtures and articles produced from certain synthetic organic materials (plastic materials) and paragraph 2 provides a restriction on cadmium and its compounds in paints (Tariff codes 3208 and 3209). The following paragraph 3 states that by way of derogation the restrictions in paragraphs 1 and 2 do not apply to articles coloured with mixtures containing cadmium for safety reasons.
There are two safety aspects in relation to this derogation. The first relates to the use of a specific colour or pigment with certain properties which is necessary to prevent accidents. The second relates to the use of a specific colour or pigment with certain properties in safety equipment.
For the enforcement purposes example of applications are given. Based on above, it can be considered that the derogation in paragraph 3 of entry 23 covers current applications of articles such as:
- Coloured wire insulation and cable jackets used in aircraft electrical and control systems for the purpose of fire detection and extinguishing systems, flight control systems or during flight tests.
The wire and cable connections are often used in in a high temperature application (greater than 150ºC ambient temperature). Cadmium pigments are used to keep the colour from changing or fading over time in the high temperature. Changing established colour conventions could introduce a significant risk of maintenance errors, which may lead to a risk of passengers.
- Outdoor safety equipment, such as:
- parts of rescue boats for ships (e.g. safety belts, water pockets of life rafts, canopies) and
- parts of safety equipment for outdoor applications (e.g. seats, reels and diverse technical parts).
The other applications that would like to benefit from the derogation need to show the similar kind of safety aspects than described above.
Such considerations should take into account the availability on the market of alternative substances which can address the safety aspects of the specific application in an equivalent manner.
See also ECHA´s report "The use of cadmium and its compounds in articles coloured for safety reasons" [PDF].