ECHA recommends companies to consult the current draft Guidance on Substances in Articles

https://www.chemnet.com   Dec 29,2010 ECHA

As from 1 June 2011, companies may have to notify to ECHA Substances of Very High Concern that are present in articles they produce and import. The latest draft of this Guidance is useful as an orientation for companies regarding their obligations for substances in articles and the decision-making process as to whether an object is an article. EU Member States still diverge on the legal interpretation of the 0.1% threshold. Further clarification on this issue is expected soon.

The guidance describes the registration, notification and communication requirements related to substances in articles and assists producers and importers of articles to identify and fulfil their obligations under REACH. Despite the dissenting views, the latest draft is very useful for companies regarding aspects that are not related to interpretation on the 0.1% threshold.

The guidance explains for example better which sources of information can be used to determine whether a substance is already registered for a use and consequently, whether registration or notification is needed. The guidance also elaborates additional borderline cases such as blasting grits, wax crayons and desiccant bags. Furthermore, it is clarified how companies can anticipate the inclusion of substances in the candidate list for authorisation. These and other improvements will allow companies to better comply with their obligations under the REACH Regulation.

Further Information

Guidance documents under consultation procedure
http://guidance.echa.europa.eu/guidance4_en.htm

Guidance on requirements for substances in articles – draft to Management Board:
http://guidance.echa.europa.eu/docs/draft_documents/Consolidated%20draft%20Guidance%20on%20requirements%20for%20SiA_MB.pdf 

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