REACH/SVHC: Obligation to Inform

There are various reporting requirements to fulfil as per the REACH/SVHC. Article 33 of the REACH Regulation sets the obligation to report within the supply chain and vis-à-vis private consumers. Manufacturers of products (called "parts" in the IMDS) have to meet their obligation to inform the receiver in the event of the presence of more than 0.1% of the gross weight of a substance included in the REACH list.

In such an event all downstream participants of the supply chain have to be informed immediately about the presence of SVHC (Substances of Very High Concern) by naming them and, if necessary, by providing information on safe handling of the same.

Conversely, as per Article 34 the obligation to inform comes into force for the user in the event of him getting new information on one of these Substances of Very High Concern. Even consumers have the right to know about the presence of SVHCs in products. They only need to enquire. Companies are obliged to reply to these queries within 45 days by naming the substance and even in this case by informing about safe handling of this substance, if necessary.

The SVHC Basic Substances in the IMDS-System

The REACH list is updated twice a year. After each update manufacturers have to check the IMDS for a change in status of the basic substances used by them that were earlier labelled as Joker (Wild Card) substances or characterised as confidential.

Should the basic substance get included in the list, the manufacturers have to compile a new material data sheet and pass it on to his clients. The IMDS system automatically checks all existing material data sheets after each update. The SVHC basic substances marked "confidential" get identified in the process and the companies affected receive a notification that the related material data sheets have to be changed.

The manufacturers have still always to check manually whether a Wild Card or Joker has been included in the SVHC list. Even in this case, if required, a new material data sheet version has to be compiled and sent to the clients. The SVHC basic substances are shown underlined on the tree in the IMDS. Material data sheets can also be manually searched for these substances (via the "Evaluations"/ "Where-used list" function).

Most of the basic substances on the REACH/SVHC list are incorporated in the GADSL, the list for banned and declarable substances in automobile manufacturing. They can then neither be marked confidential nor replaced by a Joker entry.

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