Question: My company has received a REACH Restrictions request for 15 products, each composed of several raw materials. Can we respond to these requests with the latest REACH SVHC and RoHS data, or do we need to campaign for Article 67 data specifically?
Answer: EU REACH Regulation (EC 1907/2006) Article 67 defines the requirements for restricting substances within the EU and EEA. These substances and their conditions are defined under Annex XVII (Annex 17) with ~70 entries covering a large number of substances and substance groups.
Substances restricted under Article 67 and defined under Annex XVII may have started out as an SVHC Candidate substance, then moved to the Authorisation List (Annex XIV/Annex 14) and then later restricted. Others substances may have been added directly to the restricted list because of its high potential for negative impacts.
Meanwhile, EU RoHS only includes six substance groups and four phthalates, some of which are restricted under REACH.
The bottom line is that some substances restricted under REACH are also listed as SVHCs and RoHS substances, but relying on this information alone would not provide all of the data you need to meet your communication requirements due to reporting thresholds, scope, and exemptions.
This content is accurate as of May 24, 2019.