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On June 28, 2017, the European Chemicals Agency (ECHA) published a comprehensive update to its Guidance on requirements for substances in articles. The guidance is intended to provide clarity on the communication and notification obligations of companies when substances of very high concern (SVHCs) are contained in articles.
The updated guidance includes new examples in line with the judgement of the Court of Justice of 10 September 2015, which further clarified the scope of the obligations. According to the ruling, the legal obligations also apply to articles that are present in complex products – for example, a component of a car or a washing machine. It also updates and improves the existing examples, thanks to experience gained and questions received.
Following the Court of Justice’s judgement, ECHA published a quick update of this guidance in December 2015 to correct the parts that were not consistent with the conclusions of the judgement.
This substantial update has been the subject of the normal guidance consultation process, which included a consultation with Member States, the European Commission and ECHA’s accredited stakeholders. IPC filed comments on the draft guidance in 2016 and more recently hosted ECHA guidance project lead Peter Megaw in a series of conferences.