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The Story of the Button on the Jacket—Substances of Very High Concern in Complex Products

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image of Journal for European Environmental & Planning Law

Substances of Very High Concern (SVHC) are subject to specific rules in the REACH regulation. For example, once the concentration of SVHCs in articles exceeds 0,1% weight by weight notification to ECHA and communication in the supply chain is obligatory. However, many products are in fact complex articles, consisting of many articles sometimes with SVHCs. The calculation of the concentration of SVHC in complex articles is open for interpretation due to the lack of clear definitions in the legal text of REACH. Two formulas, one defended by ECHA and the other by six Member States exist. Each has its advantages and disadvantages. The choice is not clear cut. is article tries to shed light on the issues and gives a beginning of a solution.


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