[tinwhiskers] Dispute over REACH 0.1% threshold

  • From: "Bob Landman" <rlandman@xxxxxxxxxxxxxxxxx>
  • To: "tin whiskers forum" <tinwhiskers@xxxxxxxxxxxxx>
  • Date: Thu, 18 Feb 2010 14:27:56 -0500

Dispute over REACH 0.1% threshold
Six Member States - Denmark, Sweden, Austria, Belgium France and Germany are 
pushing to resolve the long running dispute over the interpretation of REACH 
obligations relating to the presence of substances of very high concern.
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

More fun and games from the EU....

Bob Landman
H&L Instruments, LLC


Other related posts:

  • » [tinwhiskers] Dispute over REACH 0.1% threshold - Bob Landman