EU REACH: An "Evergreen" Declaration Form?

Question: A customer has asked me to fill out a EU Registration, Evaluation, Authorisation and Restriction of Chemicals (REACH) declaration form they claim is “evergreen,” so it will never be out of date. The form links to the Substances of Very High Concern (SVHC) list. The customer says this means if I sign the declaration form today, it will be valid in the future no matter what revisions are made to the SVHC list. Is this correct?

Answer: No, it is not. In fact, even if the SVHC list were static, this would still not be possible; you cannot declare a future compliance status, because the future is unknown. A declaration is valid as of the date it is provided.

Article is current as of 2020-05-29.

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