We have a question regarding REACH. The reference guide indicates that a product is compliant with credit requirements if “End use products and materials have fully inventoried chemical ingredients to 100 ppm and assess each substance against the Authorization list – Annex XIV, the Restriction list – Annex XVII and the SVHC candidate list, (the version in effect in June 2013), proving that no such substance is included in the product.”
However, article 7 of the “REACH legal text” states that manufacturers are bound to notify the agency that a substance meets REACH criteria for high concern or candidate list substances, if the substance is present in a product above a concentration of 0,1% (1000ppm), weight by weight.
We’ve received multiple credit support documents for different products in accordance with the REACH requirements stated above. By respecting REACH criteria, could we consider these products as compliant with credit requirements?