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SVHC Notification

Under REACH, producers and importers of articles (furniture, construction products, clothing etc) have a legal obligation to notify ECHA if any Substance of Very High Concern (SVHC) included in the Candidate List is present in their articles above the threshold of 0.1% weight by weight and if the quantity of such substance in those articles is over 1 tonne per producer/importer per year.

New! On 14 April 2011, CIRS successfully notifys a SHVC to ECHA on behalf of a non-EU producer of article and acquires its first SVHC notification number (starting with 03-xxx-xxxx).

Who shall submit SVHC notifications and when?

The producer or importer of the articles shall submit SVHC notifications when the following conditions are met:

• the substance has been included on the candidate list as discussed above and
• the substance is present in the articles above a concentration of 0.1% weight by weight (w/w) and
• the total amount of the substance in the articles exceeds one tonne per producer or importer per year and
• the substance has not yet been registered for that specific use.

Companies will have to notify ECHA of the presence of such a substance in their articles not later than 6 months after the inclusion of such a substance in the Candidate List. For example, for those substances included in the Candidate List by 1 December 2010, the relevant notifications have to be submitted not later than 1 June 2011.

There may be no obligation to notify if the producer or importer can exclude exposure to humans or the environment during normal or foreseeable conditions of use and disposal (Article 7(3)).

Note 1: Notification of SVHC in articles could be unnecessary in many cases. This is because the substances may have been registered for that use further up the supply chain.

Note 2: ECHA states that in multi-component articles (e.g., a car, a television, etc) the 0.1% w/w limit applies to the average concentration of the entire article as produced or imported and not the individual components.

Note 3: A notification is not required for a substance in articles which have been produced or imported before the substance has been included on the Candidate List for authorisation

When is the deadline of SVHC notification?

Companies will have to notify ECHA of the presence of such a substance in their articles not later than 6 months after the inclusion of such a substance in the Candidate List.

For example, for those substances included in the Candidate List by 19 December 2012, the relevant notifications have to be submitted not later than 19 June 2012.

However, there is a dispute about this deadline. Read more..

What information is required for SVHC notification?

• the identity of the company;
• the identity of the substance;
• the classification and labelling of the substance;
• brief description of the use of the substance in articles;
• description of the uses of the articles;
• the tonnage range of the substance contained in the articles.

Our Integrated SVHC Compliance Solutions

CIRS can carry out an assessment/testing for you or your suppliers to help you decide whether you will need to submit SVHC notifications. We also offer SVHC notification service at a very competitive price with granted success.

Our integrated SVHC solutions include:

• SVHC Testing and SVHC Assessment Report: Our certified lab provides reliable SVHC testing services and RSL screening services. We help you determine the presence and concentration of SVHC and any restricted substances in your products and issue svhc assessment report or tailor-made reports to prove that your products are compliant with REACH.
• SVHC Notification: Submit notification to European Chemical Agency (ECHA) if any SVHC on candidate list present in an article has a concentration above 0.1% (w/w) and the total amount of the SVHC exceeds 1 tonne per annum per producer or importer.
• Drafting Guidance on Safe Uses or SDS: We draft guidance document on the safe uses or provide SDS for articles containing a SVHC with a concentration above 0.1% (w/w). You can present this document to your consumers should they request it.
• Application of Authorization: We help you apply for authorization from ECHA if it is necessary to use those listed SVHCs in Annex XIV of REACH in your product.

About Us

Chemical Inspection and Regulation Service(CIRS) is a leading provider of toxic and hazardous substances testing and chemical regulatory consulting services with a strong focus on chemical compliance.

CIRS's testing lab located in mainland China has acquired the qualifications of China National Accreditation Service for Conformity Assessment (CNAS) and CMA and follows the ISO/IEC 17025.

For inquiries, please contact:

• Chemical Inspection & Regulation Service Ltd(CIRS Ireland)
  Unit 1 Ardee Business Park, Hale Street, Ardee, Co. Louth, Ireland
  Tel : +353 41 9806 916 | Fax: +353 41 9806 999
  Email: service@cirs-reach.com

 

For REACH supply chain communications & complaints, please contact Ms Alice Qian(Email: info@cirs-reach.com)