The European regulation on chemicals, REACH, introduces new information obligations for articles that contain substances of very high concern (SVHC). For such articles, producers and importers have substantial information obligations, triggered by a SVHC concentration limit. But some controversial issues concerning the application to complex articles are still under debate. They involve issues on level of protection, workability and enforceability.
This is the report from a study where 70 actors from 58 companies, industry associations and institutes were interviewed. They represent the supply chains for six product groups, namely:
- Furniture (upholstered sofa)
- Shoes (sports shoe)
- Tools (pliers)
- Toys (cuddly toy)
- Electric installations (power distribution unit)
- Electronics (desktop computer).
Results from the interviews show that gaps in the flow of SVHC information occur, in some cases it was possible to estimate the extent of this loss. Also, it was possible to clarify that the information obligations will be "diluted away" at random, without relation to exposure or risk.