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.
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