In my previous blog, “When is an article not an article?” we were awaiting the ruling from the European Court of Justice (ECJ) on whether components within articles should also be considered as articles.
The ECJ ruling on the subject has been published and it has major implications for manufactures, importers and suppliers of articles that contain SVHC’s (Substances of Very High Concern).
In essence, the 0.1% SVHC threshold for notification applies to “each of the articles incorporated as a component of a complex product” rather than to the entire article.
Wow, wait a minute there. This means that in the example I gave in the previous blog, i.e. the TV, each sub-assembly component of our TV must be treated as separate articles for the purpose of SVHC notification.
Because the ECJ ruling clarifies rather than changes the regulation, it takes immediate effect and no transition period is applicable. However, it remains to be seen how strictly the ruling will be enforced in the short term.
Confused ? Don’t be. Call H2 Compliance today for expert assistance and further information.