I have a product with a specialized screw that contains 0.32% Lead (so it is compliant for EU RoHS using exemption 6(a)). For EU REACH, do I need to report the presence of Lead as a Substance of Very High Concern (SVHC)?
It depends on which lead compound is triggering the SVHC communication requirement. Lead by itself is not an EU REACH SVHC but there are many compounds impacted by the elemental form of lead.
***Article contents valid as of 2017-09-05