EU REACH - Non-Integral Product Components

Question:

Should we seek to obtain REACH SVHC information covering a CD containing software shipped along with our product? We burn software onto a CD and include the CD with a few products. The physical CDs are retail products that we purchase from a local office supply store and are of the variety commonly available in the retail consumer market. Do we need to get REACH information covering the CD?


Answer:

Yes, the CD ROM is in scope of REACH SVHC and the compliance data should be obtained.  

There are very few items excluded from REACH SVHC, but in general it is a communication regulation, not a restriction (unless any of the substances contained in the product are placed on the Annex XVII restricted substance list).


Reference: https://echa.europa.eu/guidance-documents/guidance-on-reach?panel=guidance-on-requirements-for-substances-in-articles#guidance-on-requirements-for-substances-in-articles

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