Following the European Court of Justice (ECJ) ruling on REACH Articles Definition, ECHA has released a quick update to its Guidance on requirements for substances in articles. ECHA has updated the parts of the guidance with references to the 0.1% limit so that they are now consistent with the conclusions of the ECJ’s judgement.
The ECJ ruled that for the purposes of notification and communications obligations, no distinction is to be drawn between simple, single articles, and more complex article-within-an-article type objects. This is in relation to articles containing substances included in the Candidate List of substances of very high concern (SVHCs) in a concentration above 0.1% weight by weight.
A more comprehensive update to the guidance, due in 2016, should include a general update and re-structuring of the document, examples reflecting the court’s judgement and analysis of the current examples against the questions received and understanding gained by ECHA since the guidance was first published.
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