Technical Support on REACH Compliance for Articles
It may be noted that the EU buyers are becoming very concerned about the SVHC substances and have now started demanding their suppliers to provide proof of No SVHC content in the product and in case it’s there then to demonstrate that various requirements as is required within the REACH regulation is complied.
If the applicability analysis comes with the conclusion that SVHC(s) is present in the article, the following measures can then be adopted to achieve REACH compliance:
- Notification: Submit notification to European Chemical Agency (ECHA) if any SVHC on candidate list present in an article has a concentration above 0.1% (w/w) and the total amount of the SVHC exceeds 1 tonne per annum per producer or importer. The SVHC candidate list will be regularly updated from time to time.
- Restriction: Article suppliers not only need to comply with the requirements of SVHC, they also need to comply with the requirements of REACH Restriction. Some candidate SVHCs (for example, anthracene) are also on REACH restricted substances list (XVII of REACH). They also need to ensure that their products do not contain other REACH restricted substances.
- Authorization: Priority SVHCs on candidate list will be included in the Annex XIV of REACH (the "Authorization List"). Those SVHCs will not be allowed to be used, placed on the market or imported into the EU after a date to be set unless the company is granted an authorization.
- Drafting Guidance on Safe Uses or SDS: We draft guidance document on the safe uses or provide SDS for articles containing a SVHC with a concentration above 0.1% (w/w). You can present this document to your consumers should they request it.
- Application of Authorization: We help you apply for authorization from ECHA if it is necessary to use those listed SVHCs in Annex XIV of REACH in your product.
Communication Requirement: If any SVHC on candidate list is present in your product with a concentration above 0.1% (w/w), you are obliged to inform the recipients of the article along the supply chain about the chemical name(s) and how the article can be safely used. REACH further requires this information be made available within 45 days upon consumer request.