Since 1 June 2011 a new REACH obligation has applied affecting many suppliers of articles such as finished goods, spare parts and components. Importers and producers of articles containing Candidate List substances present above 0.1% by weight (w/w) may need to submit a notification dossier to the European Chemicals Agency, ECHA. To help you understand the new duty we have prepared this Briefing Note, which explains what is needed and when it must be done.
The Candidate List identifies selected substances of very high concern (SVHCs) that are regarded as a priority for authorisation because of very serious and often irreversible effects to human health or the environment.
Substances that may be added to the Candidate List include those which are:
The Candidate list can be found at https://echa.europa.eu/candidate-list-table.
Inclusion of a substance in the Candidate List triggers obligations for importers, producers and suppliers of articles. Some of these duties apply immediately and others have a longer deadline for companies to meet.
Article 33: Immediate and 45-day duties
From the date of inclusion, suppliers of articles must communicate immediately to business customers information on Candidate List substances present in supplied articles above 0.1% w/w. The same information must also be provided to consumers within 45 days of receiving a request. These duties are set out in Article 33 of REACH.
This Briefing Note does not discuss the definition or scope of the term “article”. If you need more information on what constitutes an article, for example whether it means a sub-component or a fully assembled product, or on the requirements of Article 33, please contact our Helpdesk at enquiries@reachready.co.uk
Many of our subscribers have asked us to draft letters they can send to their contacts addressing the key questions about responsibilities under REACH and CLP. You will find a suitable form of words you can use and we have worked hard to make sure that it will fit ...
