One of the most debated topics in respect of the REACH Regulation (1907/2006) is that of Substances in Articles.
Most of the commonly used objects in private households and industries are articles, for example, furniture, clothes, vehicles, books, toys and electronic equipment. An article may be very simple, like a wooden chair, but it could also be rather complex, like a laptop computer.
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The CE mark implications associated with the RoHS recast are already causing industry some concern.
Most popular question at the minute is when they are implemented....is it July 21st (20 days after published in the Official Journal of the European Union) or in 18 months time when transposed into national law?
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Europe has witnessed some requests around Canadian medical obligations.
The Canadian Government has required manufacturers and importers to provide information on the presence of DEHP and BPA since 2008.
The information is required for all types of medical devices including electrical and non-electrical equipment. Information on DEHP is required if it is used in the product at a concentration of greater than 0.1% of the equipment (not homogeneous material as with the RoHS Directive). Information on BPA is required for any amount so is needed even if traces are present. However, this is only required if the equipment comes into physical contact with patients or fluids such as for blood transfusions and drips.
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