ECHA has published new guidance on applicability of REACH for articles. The revised guidance offers a few more examples of what an “article” is and suggestions for how to track down whether your articles contain any Substances of Very High Concern (SVHC).
Most distressing is the introductory note from the Executive Director:
“When reading this ECHA Guidance document, please be aware that it did not find full support by consulted national authorities of EU/EEA Member States in the stage of its final consultation, as reflected in the minutes that you can access via this link.
Consequently, companies may face diverging enforcement practices as to some of its aspects." [highlight added]
They diverged on how to calculate weight percent for SVHC (reportable at >0.1 % wt/wt). Current ECHA guidance is to look at the entire weight of the imported article, whereas some countries want to look at each component separately. Dissenting countries: Denmark, France, Germany, Belgium, Austria, Sweden, Norway.
Reminder: Notification to ECHA for articles with >0.1% SVHC starts June 1, 2011. See ECHA links here.
Contact EHS Strategies, Inc. if you need help figuring out how to comply.
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- EHS Strategies Inc.
- REACH
- SVHC