W
Winterheart
Hello,
I've recently started investigating certain small EEE manufacturer's compliance with REACH Regulation and got somewhat stuck.
Equipment manufacturer is based in EU but imports some spare parts from outside EU. Spare parts supplier claims they check that raw materials they use all contain less than 0.1 % of any of the Candidate list substances, so naturally it's even less, sometimes significantly less in finished articles. Total amount of substances imported is well below 1 ton. So manufacturer has no obligations with respect to SVHC and apparently no obligations under REACH at all at the moment.
However, some of the substances in question are now included in Authorisation list and their sunset date is coming. I'm not sure if it changes anything for us.
Is there a different maximum allowable concentration for Authorisation list SVHCs?
How should we demonstrate we are not importing or selling any of these substances? Currently we have REACH compliance box ticked in specifications from spare parts suppliers and they are eager to provide test results for raw materials. Do we need to test for all SVHCs from Authorisation list, or only those past their sunset dates or is some statement from raw materials manufacturer that these substances were not intentionally added to the product enough?
I feel completely overwhelmed by the page count of REACH and all the guidelines, and the more I read the more confused I feel. Hope I can get some answers or directions on where to look for the answers here
Thanks in advance
I've recently started investigating certain small EEE manufacturer's compliance with REACH Regulation and got somewhat stuck.
Equipment manufacturer is based in EU but imports some spare parts from outside EU. Spare parts supplier claims they check that raw materials they use all contain less than 0.1 % of any of the Candidate list substances, so naturally it's even less, sometimes significantly less in finished articles. Total amount of substances imported is well below 1 ton. So manufacturer has no obligations with respect to SVHC and apparently no obligations under REACH at all at the moment.
However, some of the substances in question are now included in Authorisation list and their sunset date is coming. I'm not sure if it changes anything for us.
Is there a different maximum allowable concentration for Authorisation list SVHCs?
How should we demonstrate we are not importing or selling any of these substances? Currently we have REACH compliance box ticked in specifications from spare parts suppliers and they are eager to provide test results for raw materials. Do we need to test for all SVHCs from Authorisation list, or only those past their sunset dates or is some statement from raw materials manufacturer that these substances were not intentionally added to the product enough?
I feel completely overwhelmed by the page count of REACH and all the guidelines, and the more I read the more confused I feel. Hope I can get some answers or directions on where to look for the answers here
Thanks in advance
