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REACH Trigger for Information on Substances of Very High Concern (SVHC)

An Assessment of the 0.1% Limit in Articles

image of REACH Trigger for Information on Substances of Very High Concern (SVHC)

The European regulation on chemicals, REACH, introduces new information obligations for articles that contain substances of very high concern (SVHC). For such articles, producers and importers have substantial information obligations, triggered by a SVHC concentration limit. But some controversial issues concerning the application to complex articles are still under debate. They involve issues on level of protection, workability and enforceability. This is the report from a study where 70 actors from 58 companies, industry associations and institutes were interviewed. They represent the supply chains for six product groups, namely: - Furniture (upholstered sofa)- Shoes (sports shoe)- Tools (pliers)- Toys (cuddly toy)- Electric installations (power distribution unit)- Electronics (desktop computer). Results from the interviews show that gaps in the flow of SVHC information occur, in some cases it was possible to estimate the extent of this loss. Also, it was possible to clarify that the information obligations will be "diluted away" at random, without relation to exposure or risk.

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Findings from case studies

The article complexity of an upholstered sofa is comparably low with about 10-100 parts (e.g. frame, back, arm rest, seat and back cushion, leg, cover). The number of different materials used is also quite low: wood based materials (particleboard, fiberboard, solid wood, and plywood), polyurethane foam, plastic, steel, and textile. Spare part supply for the consumers could include covers, pillows or legs but is only to a very limited extend part of the normal business.

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