Filed under: chemicals, ECHA, EU Information, REACH/CLP | Tags: CLP; REACH; Chemicals; ECHA, SVHCs
The Advocate General to the European Court of Justice, a senior legal advisor, has issued a ruling stating that companies (manufacturers and importers) have an obligation under REACH to report the presence of substances of very high concern (SVHCs) in articles and this applies to all components incorporated into articles, not the whole article. REACH Article 33 states that companies must inform the European Chemicals Agency (ECHA) if an SVHC is present, totalling over one tonne per producer or importer per year, in a concentration higher than 0.1 % by weight.
A number of member states have considered that the obligations under REACH for companies only applied to the whole (e.g. finished) article. A good example of this would be a car, where SVHCs may be found in some specific components at appropriate concentrations, but overall would be significantly lower.
This means that companies in all member states will need to ascertain the levels of SVHCs in all components used in the assembly of any product, which will require a greater breadth of analytical testing in many cases.
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