"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.

Also, lead in glass (the 7(c)-I exemption) is generally lead oxide. This may lead to confusion, since historically it was not considered reportable as an SVHC due to the chemical composition of leaded glass. At this point, however, lead oxide in glass articles is considered an SVHC and, if present over threshold, should be included on REACH SVHC declarations. 

Finally, the concentration threshold for compliance under EU RoHS is calculated at the homogeneous material level. EU REACH sets thresholds at the article level. So the threshold calculations are made at different levels, and depending on the product in question, this may yield very different results.

 See also "EU REACH, EU RoHS, and Lead".

This content is accurate as of July 26, 2021.

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