REACH SVHC in Articles Controversy

France and Sweden have announced they will be enforcing REACH Substances of Very High Concern content in articles according to the “once an article, always an article" scheme.  Expect the other dissenting countries - Austria, Belgium, Germany and Norway - to follow.  Their position is that any component or part in an article that was ever a separate article should be counted for the >0.1% wt/wt calculation and not the article as a whole  (e.g., a belt buckle).  However, the official legal opinion of the EU and ECHA that the percentage refers to the entire article as marketed (e.g., the complete belt).

Expect lawsuits to straighten this out....