This follows the European Court of Justice landmark ruling of 10th September 2015 that articles incorporated as components of a complex product must be notified to ECHA if containing Substance of Very High Concern at above 1%. The case relates to two Articles (7(2) and 33) of the REACH Regulation and is a reversal of the previous position where the 0.1% notification applied to the entire article. ECHA is in the process of revising the relevant and more detailed Guidance, following consultation by the end of 2016.

ECHA releases a “quick update” to its Guidance for Substances in Articles