The European Chemicals Agency (ECHA) announced1 the official update of the guidance document, Guidance on requirements for substances in articles2on 28 June 2017. The update was triggered by the judgment from the European Union Court of Justice (case C-106/14). The judgment clarified the definition of an article which is known as once an article, always an article. The newly published guidance acts as a useful tool for EU importers and producers to understand corresponding articles obligation under the REACH Regulation.
The latest version clarifies the calculation of substances of very high concern (SVHC) with a number of examples e.g. bicycles, coated articles. This guidance uses a new term, “complex object”, which helps to explain the situation when several articles can be joined or assembled together in various ways. It assists EU importers and producers to comply requirements for Candidate List requirements on articles.
The update of the document was carried out via a normal guidance consultation process. This involved a full consultation including the Partner Expert Group (PEG), Member States, the European Commission and the stakeholders appointed by the ECHA. The drafts were available on the ECHA website and the last draft version3 was published in April 2017. Compared with the last draft version, no significant update was found and only some of wordings are fine-tuned in the official publication for better clarity.