June 1, 2011, articles with > 0.1% Substances of Very High Concern need to be notified to ECHA. This is a notification and not full registration as for chemicals. New guidance has been issued here.
Still a matter of dissent is how to calculate the 0.1% content for an SVHC. For now, it's still the whole article and not individual components. Here's the guidance footnote:
Dissenting views questioning the application of the 0.1% threshold to the entire article have been notified by 6 EU Member States (Austria, Belgium, Denmark, France, Germany and Sweden) and 1 EEA Member State (Norway) and publication of this part of the guidance document is currently not endorsed by these Member States. The European Chemicals Agency is working together with Member States and the Commission on a common interpretation on the application of the 0.1% threshold.
Make sure you know whether and how much SVHC are in your raw materials and final product shipped to or made in Europe. Keep up with this changing list so you can meet ongoing ECHA notification requirements. This is in addition to the customer communication requirements that trigger upon listing of an SVHC.
Contact EHS Strategies if you need help.
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