IPC Concerned about ECHA’s Draft Guidance on Substances in Articles


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On September 22, 2016, IPC submitted comments to the European Chemicals Agency (ECHA) highlighting our concerns with the draft guidance on requirements for substances in articles, version 4.0.

In the comments, IPC highlights concerns that guidance is confusing and lengthy and suggests specific changes.

On July 27, 2016 ECHA published draft guidance on the application of REACH (Registration, Evaluation and Authorization of Chemicals) to substances in articles.

The court ruling directly affects the disclosures required of articles manufacturers. The new guidance addresses the EU Court of Justice ruling on September 10, 2015 on the that levels of substances of very high concern (SVHCs) must be calculate at the level of the “simple” article, not over the weight of the entire article as imported or as provided to the customer as stated in ECHA’s 2011 guidance.

A final guide is expected by the end of 2016 or early 2017 and the EU member states are planning a six- month enforcement pilot in early 2017.

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