On September 10, 2015, the European Union (EU) Court of Justice issued a preliminary ruling on the definition of articles including components with a specific form and function that are utilized in a larger assembly. Previously, the larger assembly being imported was held to the 0.1% concentration threshold for compliance based upon the weight of a Substance of Very High Concern (SVHC) in the imported good. Based upon the recent ruling “there is no need to draw a distinction between the situation of articles incorporated as a component of a complex product and that of articles present in an isolated manner.”
The Court “rules that each of the articles incorporated as a component of a complex product is covered by the relevant duties to notify and provide information when they contain a substance of very high concern in a concentration above 0.1% of their mass.”
While this is a preliminary ruling, it is expected to be finalized. However, there is not yet a timeline on this. ECHA is preparing guidance on how reporting REACH compliance is changed and affected.
Q Point Technology is tracking the changes in this regulation, along with all other relevant details in environmental material content compliance reporting. Please continue to follow our blog for the latest news and expert advice on how to address these regulatory changes effectively.