Substances with Intended Release
Substances intended for release from articles under normal or reasonably foreseeable conditions of use are treated as normal substances or preparations. Thus, they must be registered if produced or placed on the market in quantities greater than 1 tonne per annum.
If you breached the one tonne threshold after December 1st, 2008, a late pre-registration may be submitted; however, if the threshold was breached before December 1st, 2008 and you have not already pre-registered the substance, then you must proceed with Inquiry and Immediate Registration.
Articles Containing SVHCs
Substances of Very High Concern (SVHC) are defined as substances that meet any of the following criteria:
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Carcinogenic, Mutagenic or toxic to Reproduction, Category I or II (CMR)
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Persistent, Bioaccumulative and Toxic (PBT) or very Persistent and very Bioaccumulative (vPvB)
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Of an Equivalent Level of Concern (ELC) e.g. Endocrine Disruptors
Substances identified as meeting these criteria may be nominated as candidates for inclusion in Annex XIV. Inclusion on the Candidate List triggers immediate obligations for suppliers and manufacturers of articles containing a combined 0.1% w/w or greater of one or more SVHCs.
Obligations
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Notification (From 2011 onwards) - A dossier must be submitted to ECHA detailing the substance, its classification, tonnage and use
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Communication (From date of inclusion) - Professional users of these articles must be informed of the presence of SVHC in the article and given information regarding its safe use
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Registration - Immediate registration may be required should ECHA consider the release of the substance from an article to pose a risk to human health or the environment
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Provide Information (From date of inclusion) - Requests for information regarding from the general public regarding SVHCs in articles must be responded to at no cost within 45 days
The date of inclusion above refers to the date when the SVHC is included on the candidate list. This is a varying time with groups of approximately ten substances added every 6 months.
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