Question: Many regulations require annual documentation updates. The REACH SVHC Candidate List is updated twice annually. Does this mean documentation must be updated twice per year or is once per year sufficient?
Answer — Valerie Kuntz: Under Article 33(1) of the REACH Regulation, the presence of SVHCs above threshold in articles requires communication to the next level in the supply chain immediately upon an SVHC being added to the Candidate List. There is also a requirement to provide SVHC information to consumers within 45 days of a request from the consumer (Article 33(2)).
Collecting this information annually (rather than twice per year) could prevent you from meeting these requirements.
Companies should also be aware of the Substances of Concern In articles as such or in complex objects (Products) (SCIP) database, which was established by the Waste Framework Directive. Under the new requirements, companies that operate in the EU and import or manufacture articles with SVHCs over threshold per Article 33 of the REACH Regulation must enter the SVHC, article and product information into the database. This information will need to be available and entered into the database by January 5, 2021. This requirement will further enforce that the communication duties established under the REACH Regulation are properly followed.
Article is current as of 2020-04-17.