On the Relative Importance of Substance Test Information in Demonstrating REACH Compliance

Question Posed:

What is the importance of getting individual test reports for specific products, when compared with a strategy of building out a parts database that compliance data can be mapped to (as both can be considered strategies to support REACH SVHC compliance)?

Answer Provided:

Many regulations and directives require test reports of the items to be part of their technical documentation. The Chemical Safety Assessment (CSA) requirement for EU REACH is the process that identifies and describes the conditions under which the manufacturing and use of a substance is considered to be safe. Obtaining CSA information is often an important step in compiling a Registration Dossier for substances manufactured or imported into the EU over one tonne/year. There are three major steps in the CSA process. These are:

  • Hazard assessment
  • Exposure assessment
  • Risk characterization

While there isn't a specific testing requirement for EU REACH, having the information to provide the data when you can't get it from suppliers is often necessary to confirm you don't have specific substance(s) in your product.

Testing normally only looks at specific common substances, it does not normally test to find all the substances included in the product or even all regulated substances unless specifically requested. When requested to do a specific substance list or full substance test on a product, the cost for the tests increase significantly, so full testing of all their products could get very expensive.

Using Assent’s services can help you obtain information on specific restricted substances from multiple levels of your supply chain. This information can help you ascertain which substances are included in parts, sub-assemblies, or finished goods that need to be communicated to other stakeholders, or help determine whether your organization might encounter unforeseen restrictions to specific markets due to product materials introduced by your suppliers.

Reference (Details on CSA): https://echa.europa.eu/guidance-documents/guidance-on-information-requirements-and-chemical-safety-assessment

**Article contents valid as of 2017-06-15

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