When Declarations and Laboratory Testing Disagree

Question: A supplier previously declared that an article contained a specific regulated substance, but our lab test shows the substance is not present. How should we approach this discrepancy?

Answer: Some substances are challenging to definitively identify through testing. Your test’s outcomes could have been influenced by a number of factors, including the part being tested, the substance being tested for, the sample size, and/or the testing methodology. For example, some substances are difficult to test for in certain types of materials, or the sample size used may have been too small to return accurate results.

Once you understand these factors, I suggest discussing this with your supplier. They may be able to give more context to their declaration. For instance, there may be a known risk of intermittent contamination, which a spot test might not catch. It’s even possible that the supplier made a mistake in their declaration.

Laboratory testing is an invaluable source of information, but it isn’t foolproof. Section 5.2 of the European Chemical Agency (ECHA)’s Guidance on requirements for substances in articles details some potential challenges and considerations.

Article is current as of 2020-07-24.

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