REACH: SVHC in Articles

Controversy remains on the notification and communication requirements for Substances of Very High Concern (SVHC) in articles.  Do you calculate the >0.1% wt/wt SVHC  according to each component or for the finished article as placed on the market?  Several countries (AUSTRIA, BELGIUM, GERMANY, FRANCE, NORWAY, SWEDEN ) say it's by component and tough luck on importers: "Once an Article - Always an Article."  ECHA says it's the entire article.  The court will have to decide. But no lawsuits yet.

Here's Germany's guidance on the matter: pdf

EHS Strategies, Inc. can help you decide how to deal with these requirements.