CLP Enforcement Project
11 November 2016, the Forum held its 25th plenary meeting where it decided the subject of its sixth major coordinated enforcement project REACH-EN-FORCE-6 (REF-6). The project focus on the classification and labelling of mixtures including the check of relevant parts of the SDS.
The project will be prepared in 2017 and inspections will take place in 2018. Publication of the report is expected near the end of 2019.
SVHC Enforcement Project
Forum pilot project on internet sales have started. The inspectors check if sellers provide the required information when selling hazardous chemicals online.
The Forum started preparations for the pilot project on substances in articles with the intention to initiate inspections in 2017. The project will look into the duty to notify substances of very high concern (SVHCs) in articles and the requirements for communicating information on SVHCs in the supply chain.
Background 1: Obligations of SVHC
| Object | Articles | Substance /mixture |
| Obligations | SVHC > 0.1% (w/w): Supplier shall provide the recipient of the article with sufficient information, available to the supplier, to allow safe use of the article including, as a minimum, the name of that substance. On request by a consumer the relevant information shall be provided by any supplier of an article free of charge, within 45 days of receipt of the request. If the substance is present in those articles in quantities totalling over 1 tonne per producer, supplier shall notify ECHA. | Supplier of SVHC substance or mixture shall provide the recipient with SDS. Mixture SVHC > 0.1% supplier shall provide the recipient with SDS. |
Background 2: SVHC New Investigation Methods
On 10 September 2015, European Court of Justice (ECJ) has said the 0.1% threshold for notifying SVHCs in articles applies to “each of the articles incorporated as a component of a complex product” rather than to the entire.
The SVHC new Investigation Methods is more stringent, its requirements about communicating information of supply chain is higher.
CTI Suggestion
REACH-EN-FORCE look into obligations of (SVHCs in articles in the supply chain. It require enterprises to the correct understanding of the calculation method of SVHC concentration, and preparation and application of standardized SDS, and then according the regulatory requirements to fulfill the obligation of notification and communicating information on SVHC in supply chain . Reduce the risk of product REACH violation.
CTI Service
As the third party inspection Institution, CTI becomes the first publicly traded company on the Chinese Stock Exchange. We can provide testing, inspection, audit and certification services to consumers. Moreover, we can also provide professional and comprehensive quality solutions to improve the competitiveness of your products in the global market.
粤公网安备 44030602000441号