The issue of whether the Substances of Very High Concern (SVHC) in articles is triggered at >0.1% weight of chemical to weight of the entire article placed on the market or to any component of that article remains controversial according to discussions at the September 23, 2011 REACH workshop.  ECHA guidance is still holding with the entire article weight in the denominator, but acknowledges that some member countries are saying they will enforce the RoHS approach on each component part.  ECHA and The European Commission are looking at how to resolve this issue.

Odds are good that this one is going to the European Court of Justice.

Leave a reply