BIH: Is My Product a Chemical? – Part Two

Last week, I wrote about the definitions of "chemical" and "product," how this can help you in practice, and why confusion arises. Today, we'll look at a few more examples and teach you how to determine if your product is a chemical.

On Tuesday, I left you with the question of whether a car air freshener is a chemical or a product.

By the end of this text, you should be able to answer that question yourself.

When there are uncertainties about certain products, it's necessary to determine the following:

• what the function of the product is, or its intended purpose, and
• whether the product contains a substance or a mixture.

You might think some products don't contain chemicals. However, most products, especially industrial ones, do. They are used to enhance certain functional properties (plasticizers), appearance (color), longevity (preservatives), and so on.

Now, ask yourself the following questions:

• What determines the function of the product?
• Does that function depend on the chemical composition of the product or its shape, surface, or design?
• Can the present substance or mixture be released from the product or consumed during its intended use?
• Does the product retain its function if the chemical is removed from it?
• Can the removed chemical serve the intended purpose of the product without its physical components or design?

Let's try this with the example of a PET bottle. (PET bottles are made from polyethylene terephthalate (PET) and are produced through a thermal reshaping process).

The function of the bottle is to physically hold liquid content (e.g., packaging for dishwashing detergent). The product is chemically composed (PET). However, the function of the product is primarily determined by the shape of the bottle. After use, the bottle still retains its function, and the chemical it is made from remains unchanged.

In this case, it's clear that we're dealing with a product.

Now, let's return to car air fresheners.

The function of a car air freshener is to refresh the space – releasing fragrant substances into the air. It contains fragrant substances on a carrier (e.g., cardboard) of a specific design. In this case, the function of the product is determined by its chemical composition. During its intended use, the fragrant substances are released from the product. Once all substances are released, the cardboard carrier, regardless of its shape, cannot perform the function.

So, we can conclude that this time it's a chemical. Did you guess right?

Why is all this important?

Chemical regulations impose different obligations for chemicals and products. For products, these obligations are significantly less. They mainly involve the obligation to inform customers about the presence of substances, but only if they are considered of particular concern.

And yes, dishwashing detergent is indeed a chemical, not just an "ordinary product."

If you're unsure whether your product line contains chemicals, contact me at nina.pajovic@bens-consulting.eu.