"No SVHCs" Declarations for Products Containing Lead

Q: I’ve encountered supplier declarations for the same product that declares “No SVHCs” for REACH, and “Contains lead according to exemption 7c-I” under EU RoHS.” Why is this?

A: Substances regulated by EU RoHS include lead and lead compounds, while  REACH regulates certain lead substances, but not all. Follow up with the supplier in these cases to confirm which specific lead substance is being declared under EU RoHS. In general, lead in glass (the 7(c)-I exemption) is usually lead oxide rather than pure lead. That’s why it wouldn’t be declared under REACH.

Also, under EU RoHS, the threshold for compliance is calculated at the homogeneous level. EU REACH sets thresholds at the article level. So the threshold calculation is made against the article level of the part the substance is found in, rather than the final product in its entirety.

 

This content is accurate as of March 1, 2019.

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