Question: My company has a robust due diligence program based on the Aerospace and Defence Declarable Substance List (AD-DSL). We believe substances from the REACH Substances of Very High Concern (SVHC) and Annex XIV lists should already be captured in our AD-DSL surveys. Is there any reason we should have to campaign separately for the SVHC or Annex XIV substance compliance information?
Answer: While the AD-DSL does contain substances from the REACH SVHC and Annex XIV (Authorisation) lists, the REACH Candidate List of SVHCs is updated twice annually, while the AD-DSL is only updated approximately every 12 months.
Given the differences in update frequency, the AD-DSL should be compared to the latest official EU REACH SVHC and Annex XIV lists prior to making an assumption that these substances are also covered in a given release of the AD-DSL.
Article is current as of 2020-06-12.