BIH: Is My Product a Chemical? – Part One

Do you sometimes find the term "product" confusing when it comes to chemical legislation?

Before we begin, a quick note. I've divided this article into two parts for two reasons. First, it's packed with information, so we'll take it slow to avoid overload. The second reason is purely practical; the article would be too long otherwise.

Let's return to the term "product" and how you might define it.

I know most of you, like me, are used to using the term "product" for a finished chemical product (e.g., dish detergent, wood paint, air freshener).

Often, in conversations with clients, I hear: "We don't sell chemicals; we have regular products like dish detergents."

However, if we take a closer look at the definitions from the Chemicals Act, we'll realize that we mostly use the term "product" incorrectly.

The confusion mainly arises from the unclear translation of the term. In English, the terms "product" and "article" are commonly used, but in our language, they are usually translated as the same term – "proizvod."

The general term "product" refers to any goods that are produced, sold, or used. This is what we commonly refer to as a "product," even when it involves a chemical.

The term "article," however, more specifically refers to a shaped object, or product, as defined by chemical regulations.

Let's recall the definitions from the Chemicals Act.

"Chemical" means a substance or a mixture containing multiple substances."

"Product" refers to an item that has been given a specific shape, surface, or design during production that determines its function more than its chemical composition."

According to these definitions, products include finished items like plastic packaging, phones, pants, or cars. Although these products contain substances, their function is determined more by their shape, surface, or design than by their chemical composition.

Room spray freshener is also a finished product commonly used in households. However, it is a product composed of multiple substances, which defines its function. In this case, it is a chemical, specifically a mixture.

However, it's not always easy to draw the line between these two groups. I'll write more about this next Tuesday.

Until then, consider another example - car air freshener trees. Again, it's a space freshener. But this time, its shape is defined and doesn't change during use. Is it a chemical or a product?

The answer is coming next week.

If you're unsure whether your product range includes chemicals or can't wait for the second part of this article, contact me at nina.pajovic@bens-consulting.eu.