REACH SVHC Article definition

Current ECHA guidance regarding calculation of the 0.1% threshold would regard only a selling unit as a complete article. So the complete article approach is currently not only that of ECHA but also that of most other EU-Nations.

A simple illustration of both principles of belt containing a buckle and a strap is shown below:

According to the “once an article always an article approach,” before the belt was manufactured, the strap was an article and the buckle was an article. Therefore if the SVHC was present above 0.1% in the strap, the SVHC obligations would apply irrespective of the weight of the buckle. If the current ECHA guideline is followed, the weight of the buckle is changing the weight distribution so that the SVHC share of the Article “Belt” stays below 0.1% and the obligation for information does not apply.

Irrespective to the approach for calculating SVHC content the guidance document, issued by the six dissenting nations, contains useful information and supplies worked examples of how to calculate the overall weight of chemicals present for a whole range of consumer items from printed T – Shirts; Electrical Cables; Desktop Computers, Kitchenware etc.

Bureau Veritas will inform clients of developments in this area since in the longer term the current situation has to be resolved by the members of the European Union.

http://www.kemi.se/Documents/Forfattningar/Reach/Guidance_for_suppliers_of_articles_EN.pdf