4. Are your obligations the same for all EU countries?

REACh ( cf. REACh: understanding the main principles and procedures [FIC 0121] ) is a European regulation, and is therefore applicable in the same way throughout the EEA (it does not need to be transposed into national law). However, the definition of article is taken into account differently:

• a majority of EEA countries consider that the notion of article refers to an object in its entirety;

• on the other hand, some countries consider that an item can be made up of one or more objects meeting the definition of an item (notion of sub-item).

In the latter case, the notification and communication obligation applies to each sub-article. The countries concerned by this approach are France,...