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.

http://echa.europa.eu/view-article/-/journal_content/title/guidance-on-substances-in-articles-updated

http://curia.europa.eu/jcms/upload/docs/application/pdf/2015-09/cp150100en.pdf

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