Six Member States -
The current interpretation of the threshold is 0.1% by weight of the total article while the six countries feel that the 0.1% threshold should apply per component part.
Various case studies to support the argument that applying the threshold on a per component basis is more workable for industry, more enforceable by REACH authorities and would reduce potential information gaps on SVHCs.
However, the European Commission made it clear that it was not persuaded to change its interpretation and, as a result, the European Chemicals Agency said it could not change the guidance.
Gathering SVHC information from manufacturers at the top of the supply chain is still proving to be a challenge. While this is the same across many industries there seems to be little that the enforcers can do even though, as a result, companies are breaking the law. It is also considered a breech of the regulations to cause a downstream customer to break the law.
14 new SVHCs have been added to the original15 so the substance data collection that many have been working on for a year or more has to start all over again.
Directive Decoder
Gary Nevison, Head of Legislation at