INFORMATION OBLIGATION UNDER ARTICLE 33 OF THE REACH REGULATION
REACH, the European Chemicals Regulation, must be implemented in all EU Member States since 1 January 2007. Since 28 October 2008, the candidate list of SVHC substances1 has been published under Article 59 (1, 1 0) of Regulation (EC) No 1907/2006 ("REACH") and is available on the ECHA website:
Following the SVHC identification procedure, the European Chemicals Agency ECHA added lead metal (EC No. 231-100-4 I CAS No. 7439-92-1) to the REACH candidate list on 27 June 2018.
The inclusion of a substance on the EU candidate list results in information obligations in the supply chain:
If the limit value of 0.1m% of a substance of very high concern (SVHC) is exceeded in a component part of a product, information must be provided in accordance with Art. 33 (1) of the REACH Regulation - irrespective of the m% proportion in the total product.
Some of our products (own production/commercial articles) are affected by this information obligation due to the inclusion of lead metal on the REACH candidate list. The affected products will be provided with the following information on our invoices: **Duty to inform according to Art. 33 REACH regulation (SVHC candidate list): Articles contain more than 0.1% lead (EC-No. 231-100-4 I CAS-No. (EC-list) 7439-92-1)".
To our knowledge, there is no ban on the use of lead on the basis of the SVHC candidate list. We would like to point out that a detailed information on the exact mass concentrations of our products listed in our catalogue is not feasible due to our large product portfolio. We are monitoring the candidate list and are in contact with our suppliers in order to keep our information.