UEAPME criticizes REACH guidelines for failing to assist SMEs in complying with SVHC obligations in finished products
UEAPME criticized the REACH guidelines for being unable to help small and medium-sized enterprises comply with their obligations on SVHC in finished products. Last month, the European Chemical Agency (ECHA) issued an updated guidance (Guidance on requirements for substances in articles) to assist manufacturers in understanding if finished products contain high levels of SVHC. Substances of concern (SVHC), in order to comply with the requirements of REACH regulations, manufacturers must prepare information and respond. The European Association of Craft, Small and Medium-sized Enterprises (UEAPME) pointed out that the case studies cited in the guidelines published by ECHA are not of substantial help to small and medium-sized enterprises. In 2015, ECHA ruled that when identifying whether the SVHC content in a finished product exceeds 0.11% by weight of TP3T, the definition of the finished product must be uniformly standardized within the EU, thus interpreting the finished product. The single entities contained and composed of an article are regarded as finished products under the REACH regulations. Therefore, in a relatively complex product, its numerous components will be regarded as individual finished products. Therefore, component suppliers are also given the responsibility to communicate SVHC information in the REACH regulations. For REACH Regulation 7(2), the SVHC content in the finished product exceeds 0.1%