REACH Obligations for Substances of Very High Concern and Articles

REACH obligations for Substances of Very High Concern and Articles

After a substance is designated a Substance of Very High Concern (SVHC) under REACH, a number of legal obligations apply. Producers and importers of articles containing SVHCs have to provide sufficient information to allow their customers to use the articles safely and may need to submit notifications to the European Chemicals Agency (ECHA). Articles as defined in REACH range from simple objects, such as a screw, to complex objects, such as a car.

No later than six months after a substance is designated an SVHC, companies must notify ECHA of the SVHCs that are included in their articles (“substance notification”) if certain conditions are met.

From 5 January 2021, a further regulation takes effect, requiring companies supplying articles containing SVHCs above a concentration of 0.1% to make additional notifications to ECHA. These notifications will populate a new database for information on substances of concern in articles or complex objects (products)—the SCIP Database—which will be used for waste management purposes. Preparing and submitting article notifications can be complex, requiring a specialist understanding of REACH. Notifications can be prepared from October 2020 and must be in place from 5 January 2021.

How Exponent Can Help

Exponent provides a complete service to assist companies with the management of their SVHCs, including their notification obligations. Our staff have strong scientific and regulatory expertise from prior experience in industry, in contract research, and, in many cases, as a regulators (including with ECHA) before joining Exponent, making them ideally positioned to help clients navigate their REACH obligations.

We can support your team to prepare your SCIP Database notifications or provide a full service by acting as your representative. Examples of assistance we can provide are:

  • Full project management and documentation – Management of all aspects of SVHCs, efficient communication, regular updates on progress, and completion and submission of all necessary documentation to ECHA.

  • Regulatory intelligence – Monitoring regulatory processes and providing alerts about key developments.

  • IUCLID support - Preparation and submission of substance and article notifications in UCLID (International Uniform Chemical Information Database) format with links to any other necessary notifications.

  • Determination of notification requirements - Assistance identifying your articles as defined in REACH that require notification.

  • Information requirements - Clarification of the information required for notification.

  • Follow up - Assistance with follow up queries or requested actions from ECHA.

With offices and experts in the UK, EU, US, and Asia, we offer a comprehensive range of technical and regulatory expertise to help companies meet their REACH obligations.