As already reported in April, according to the European Chemicals Agency (ECHA), the notification of articles containing SVHCs is mandatory from 5 January 2021, following the amendment to EU Directive 2018/851. SVHC stands for “Substances of Very High Concern”. All articles containing more than 0.1% by mass of SVHC substances are subject to compulsory notification. In particular, articles such as CdTe photovoltaic modules are subject to notification due to their product characteristics. Many other electrical and electronic equipment may also be affected, as heavy metal compounds and flame retardants are also included in the SVHC list.
For purposes of specifying the EU SCIP (Substances of Concern in articles as such or in complex objects (Products)) database has now been completed. Entry of SVHC substances is mandatory as of 5 January 2021. Parties affected include all those who use aluminium and brass alloys in their products. For machining reasons, these often have a lead content of more than 0.1%. The sale of these alloys remains permitted, but is then subject to mandatory registration.
Recommendation: Please make timely preparations for such mandatory notification so that you or your suppliers have sufficient lead time until 5 January 2021.
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