REACH due dilligence and meeting the ever moving SVHC target

qu1nn

Involved In Discussions
#1
I work for a manufacturer of weight scales that sells into the European Union where REACH is a requirement.


Most of the products mass is in the steel load cell (~75%).


We have had the entire weigh scale 3rd party tested to SVHC = 151 and everything was under the reporting limits. Seeing that the the SVHC list continues to grow (now currently up to 161 candidates) would it be acceptable to rely upon the test report as 3rd party objective evidence (at 151) and since a majority of the mass is the load cell itself would make any future candidate testing unnecessary to test for, especially if there is no bill of material changes?


Thank you for your time
qu1nn
 
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qpled

Involved In Discussions
#3
That sounds reasonable since you are declaring which REACh list you are in compliance with and your BOM is available if it needs to be checked for future additions to the REACh list.
 

Alex73

Involved In Discussions
#4
If a substance listed on the Candidate List is contained in a article, this will trigger some obligations: article 7.2 (notification) and article 33 (communication of information).


Only Representatives (or Importers) of imported articles containing SVHCs included on the Candidate List (as defined in Article 57 of the REACH Regulation) in a concentration above 0.1% (w/w) shall provide relevant safety information about the substance to the recipients of these articles (Article 33.1).

On the other hand, Only Representatives (or Importers) need to notify ECHA when both conditions of Article 7.2 are met:
* The substance is present in articles imported above a concentration of 0.1% (w/w);
* The total amount of the substance present in all articles imported, which contain more than 0.1% (w/w) of the substance, exceeds 1 tonne per year.

Since your company is located outside EU/EEA, it should be enough to know only all substances with composition of 0.1%, or higher, present in the article.

Why?
Imagine you find a SVHC, in the article, with a composition of e.g. 0.09% then no action is needed because the criterion defined in articles 7.2 and/or 33 are not meet. On the other hand, if a SVHC is present, in the article, with a composition of e.g. 0.11% then you must inform your customers (article 33) and notify ECHA if the total volume imported (into EU/EEA) is above one ton per year (article 7.2).


I think that should not be difficult to obtain the composition of all substances for which the composition is at least 0.1% (w/w) because your company should be working with very pure/stable alloys.


Alex.
 
L

lday38

#5
Thats the best explantion I have seen. Thank you for posting it. Is there also a must for information on sds sheets or safe handling when it exceeds .1%

Lin
 

Alex73

Involved In Discussions
#6
If an article (e.g. a weight scale) contains a SVHC in a concentration above 0.1% then enough information to allow its safe use shall be provided. According to article 33, the minimum of information is the substance name.

Alex.
 
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