Notification of substances in articles is required of producers and exporters of products(known as articles within REACH) when all conditions of Article 7(2) of REACH Regulation are met:
- The substance is included in the Candidate List for authorization (REACH SVHC List).
- The substance is present in product produced and/or exported above a concentration of 0.1% (w/w).
- The total amount of the substance present in all products produced and/or exported, which contain more than 0.1% (w/w) of the substance, exceeds 1 tonne per actor per year.
Important to Note:
- The substance concentration threshold of 0.1% (w/w) applies to the product as
produced or exported. In practice, however, companies may already be collecting information not only on the whole product but also on parts thereof.
- Companies may, on a voluntary basis, prepare their notification to be submitted to ECHA on this basis.
- The obligation to notify substances in products also applies to packaging materials, which may be exported separately as packaging of exported goods.
- Packaging is to be assessed separately from any object it contains.
How to submit a notification?
Non-EU producers and exporters can submit SVHC notification, if the exported product fulfils all three conditions mentioned above, to ECHA by appointing an “Only Representative” based in EU. Contact SSS for more details.
- A notification of substances in products shall be made at the latest
6 months after it has been included on the Candidate List of Substances
of Very High Concern for
authorisation, but only starting from 1 June 2011.
- This means that for substances included in the Candidate List before 1 December 2010, the notifications have to be submitted not later than 1 June 2011.
- For substances included in the Candidate List on or after 1 December 2010, the notifications have to be submitted no later than 6 months after the inclusion.