A Forum pilot enforcement project in 15 participating countries has found that 12 % of inspected products contain substances of very high concern (SVHCs). The majority (88 %) of suppliers of these products are failing to communicate sufficient information to their customers about SVHCs in products they supply.
Helsinki, 18 November 2019 – The results of the pilot project show that companies need to improve their knowledge on the products they supply to their customers and to better communicate information so that products containing substances of very high concern can be used safely.
In this project, 405 companies across 15 countries were inspected and 682 articles were checked. 84 (12 %) of the 682 articles were found to contain substances listed as being of high concern to human health or the environment (Candidate List substances) in concentrations above 0.1 % weight by weight.
The products checked by inspectors were selected especially as they were highly likely to contain targeted Candidate List substances. Such products included clothing, footwear and home textiles; wires, cables and electronic accessories; plastic or textile floorings; wall coverings; and other plastic and rubber products.
“While nearly 90 % of the products do not contain substances of very high concern above 0.1 %, the report clearly shows a failure of communication in the supply chain. Improvement is needed if we want to make REACH work in all aspects, contribute to the objectives of the circular economy and to have a good database as required under the Waste Framework Directive,” says Erwin Annys, Head of ECHA’s Support and Enforcement Unit.
The duty to communicate information down the supply chain about the presence of Candidate List substances in articles was applicable to 45 articles containing those substances. Suppliers did not do so for 40 (89 %) of them, and 37 out of 42 companies (88 %) failed to provide the name of the substance to recipients of their articles.
For companies supplying articles directly to consumers only, 22 suppliers (51 %) out of 43 were considered to have insufficient information available to fulfil their obligation to provide required information to consumers, when requested. The results show that, in almost all cases, only the name of the Candidate List substance was communicated in the supply chain, and this may not be sufficient to allow safe handling.
For the 12 % of articles placed on the EU market containing Candidate List substances, the results of the project show a high rate of non-compliance. This situation hinders the safe use of Candidate List substances in produced and imported articles, in particular those used by consumers.
The ECHA Secretariat and the Forum will further analyse the results from this enforcement project and the recommendations included in the Forum’s final report, and consider further actions that could improve the situation.
The Forum for Exchange of Information on Enforcement (Forum) is a network of authorities responsible for the enforcement of the REACH, CLP, BPR, PIC and POP regulations in the EU, Norway, Iceland and Liechtenstein.
The term ‘product’ in this text refers to an article, defined by REACH as ‘an object which during production is given a special shape, surface or design which determines its function to a greater degree than does its chemical composition’.
Patrokles QA Manager – Quality Assurance Done Right
We have recognised that managing all aspects of product compliance, including meeting your obligations to communicate the presence of SVHC in articles sold to EU consumers, requires not just domain knowledge but also a dedicated software solution to streamline day to day activities that quickly spiral out of control if shared file storage, spreadsheets and email are the only tools at your disposal.