At an EU workshop at the beginning of June, Erwin Annys, REACH director of the European Chemical Industry Council (CEFIC), criticized suppliers from non-EU countries. Such suppliers often have too little or no information on EU regulation on dealing with substances of very high concern (SVHC).
Article 33 of the REACH Regulation requires all suppliers to inform their customers if a substance contains SVHC and how to deal with the substance when it is present in a concentration of greater than 0.1%. See our blog: SVHC – EU Court Contradicts the ECHA. The article also requires suppliers, upon request, to inform consumers within 45 days if a product might contain SVHC.
Suppliers generally fail to comply with both obligations or do so inadequately, says Annys. That’s why he sees Article 33 as the greatest weakness of the REACH Regulation. In his opinion, the regulation leaves too many questions open. It must formulate more precisely what information the supplier must provide and how the information is to be communicated.
Annys appealed to industry associations to find solutions. For example, they could provide suppliers with a uniform format to be used when providing information. Only a global solution will help, he says.
Do your products contain SVHC and do you want to be sure about their legal compliance? Please contact us at any time at firstname.lastname@example.org.