What is the Notification of SVHC?
According to REACH Regulation, producers and importers have to notify ECHA of the substances listed on the Candidate List which are present in their articles, if both the following conditions are met:
(1) The substance is present in their relevant articles above a concentration of 0.1% weight by weight.
(2) The substance is present in these relevant articles in quantities totalling over 1 tonne per year. Companies have to notify the inclusion of the substance in the Candidate List no later than six months.
Who Need to Submit Notification?
• EU producers
• EU Importers
• Non-EU producers (non-EU-manufacturers may submit notification by appointing an EU-based Only Representative to notify on their behalf).
When to Submit Notification?
• The substances being added in the Updated Candidate List before 1 December 2010 shall be notified before 1 June 2011;
• The substances being added in the Updated Candidate List after 1 December 2010 shall be notified within a 6-month period.
Why Should Submit Notification?
Products can only be produced or imported in EU if they conform to REACH Regulation. The EU state members have passed strict measures of supervision and punishment under REACH Regulation. EU customers are entitled to carry out the inspection of REACH compliance. Importers or producers will be punished by recall, penalty, even the imprisonment for some REACH violations.
The Procedure for SVHC Notification
A notification is not required provided the one of the following occurs:
(1) The producer or importer of an article can exclude the exposure of human and the environment with the substance during normal or reasonably foreseeable conditions of use of the article, including its disposal. In this case, the producers and importers will give appropriate instructions to the recipients of the article.
(2) The substance has already been registered by a manufacturer or importer in the EU for that use.
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