You indicated that there is no legislation for cards; would they not need to comply with REACH?

REACH only really applies to importers of chemicals. Downstream users and consumers do not have to. A lot depends on the chemicals you are importing to produce the cards. If you are just importing completed cards and distributing or retailing them this should not be a major impact. That said Cards are now moving into Product Group 3 as from Issue 3 of the Consumer Product Standard so this potential issue is captured.

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