As happened with the RoHS Directive, clarification has been sought on how to define the concentration limit featured in the REACH regulations.
REACH requires either informing the authorities or notifying a customer of the presence of a substance in an article (product) under certain circumstances.
Once again the guidance is if the concentration of the substance is greater than 0.1% by weight.
As with the RoHS Directive there has been much debate concerning how this percentage is defined-by homogeneous material is one option as used by RoHS, another is as a proportion of the whole article.
New guidance states the following:
“The substance concentration threshold of 0.1% by weight applies to the article as produced or imported. It does not relate to the homogeneous materials or part of an article, as it may in other legislation, but relates to the article as such (ie as produced or imported)”
This clarifies that the percentage weight applies as a portion of the article.
Directive Decoder