Regarding on the SVHC in the article, what is meant by 0.1% by weight? Is it against the entire article, homogenous material or something else?
The REACH regulation stated that SVHC notification trigger is for those substances “in a concentration above 0.1% (w/w)”. The guidance document published by ECHA in May 2008 further clarified this to mean 0.1% weight by article weight, rather than at the homogenous material level. However, several EU member states including Austria, Belgium, Denmark, France, Germany, and Sweden have explicitly disagreed with this interpretation and argued the validity of the homogenous material/component level to ensure the protection of human health and the environment. While the legal interpretation needs to be resolved by a European Court, clients are recommended to consider the worst-case scenario (i.e. homogenous material/component level).
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