The European Chemicals Agency (ECHA) released the latest draft guidance1 on substances in articles. This guidance incorporated the comments from the Partner Expert Group (PEG). This group was composed of experts from the various stakeholders and appropriate national authorities for the relevant Regulations. Originally, it was expected that the guidance would be finalised and released in the early 2017. However, it was delayed because a lot of PEG’s comments2 were received. The final version of the guidance should be ready in July or August 2017.
The revision of the guidance was triggered by the European Court of Justice ruling in 2015. The interpretation of articles was clarified. “Once it is an article, it is always an article". Previously, the calculation of SVHC was by the weight of the entire article. However, it is now evaluated based on each article. The guidance on substances in articles was revised as version 3.0 via the fast track process in 2015. Corrections were made to the sections with references to the 0.1% limit. A formal revision of the guidance is on-going with a proper consultation procedure. The current draft will be ready for the forum consultation and to be commented by the competent authorities for REACH and CLP.
Comparing with the previous draft sent to the PEG3, the current one targets to cover more audience in the market. The wordings in the current version is fine-tuned. Simplified examples and illustration are included. This version explained how the concentration of the SVHC in articles should be calculated.
The mixture used to join the two or more articles together. The concentration of substances of very high concern (SVHC) is calculated over the total weight of the article.
Full or partially coated articles should be calculated over the total weight of the article.