ECHA has issued a new Guidance in a Nutshell for REACH requirements for articles:

Regarding how to calculate 0.1% wt/wt of Substances of Very High Concern, it says:

The substance concentration threshold of 0.1% (w/w) applies to the article as produced or imported. In practice, however, companies may already be collecting information not only on the whole article but also on parts thereof. Companies may, on a voluntary basis, prepare their notification to ECHA on this basis.

See my previous item on dissenting countries.

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