As part of the breakthrough change, the court mentioned that “the REACH Regulation’s definition of an “article”, taken together with the lack of any provisions specifically addressing the situation of a complex product containing several articles, means “there is no need to draw a distinction between the situation of articles incorporated as a component of a complex product and that of articles.”

The Advocate General, last year ( 18th February, 2015) had opined to ECJ that the 0.1% threshold should apply to each component separately and not to the whole article. Since the verdict has now been endorsed completely without any modifications by ECJ, REACH compliance will get stricter for companies selling products in the EU market. This would further result in increased compliance burden for manufacturers, importers and distributors differently, thereby ensuring that companies get their practices in line with the modified regulation.

ECJ’s decision comes in line with the views of the 5 EU member states and Norway (member of European Economic Area-EEA) but it contradicts the earlier view adopted by EC and ECHA.

As per REACH, when the article contains an SVHC in a concentration >0.1% then manufacturers should provide the information about the inclusion and safe use of the chemicals to the customers. Now after the ECJs ruling, the 0.1% threshold is no longer calculated on the basis of the whole article (former ECHA interpretation) but of “each of the articles incorporated as a component of a complex product.”

This ruling will have a huge impact in the manufacturing industry as it increases the burden of REACH compliance in companies at a deeper and complex level. It will affect the way samples are analyzed (at the component level), the number of analysis to be conducted, and how they are reported under to become compliant.

There will also be a substantial impact on REACH documentation, since manufacturers of finished electronic products will need to have a REACH declaration for each individual component before the complete product could be declared. Some manufacturers may need hundreds of declarations from their suppliers so as to confirm their products as ‘not containing SVHC’.

With respect to SVHC notification, EU producers and importers would have to notify listed SVHC’s above the threshold in each component (possibly including sub-assemblies) they produce/import and in the article as a whole. Suppliers or downstream users have to collect declarations from the producers for the products they supply (and each component the product contains, if required) and pass it to the customers.

A person supplying a product with one or more constituent articles containing an SVHC above the threshold will have to make sure that he receives all the required declarations for the article as a whole and for each component inside the article from the manufacturer.  So in fact the enquiries to manufacturing companies will increase in huge number as a result of this ruling of ECJ and the compliance burden would thereby drastically increase in the testing as well as documentation side for the manufacturers of finished electronic products.

For the future, lots of clarifications and guidance required from ECHA for manufacturers on how to handle the new changes in REACH and the guidelines needs to be modified by ECHA.

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However, it creates a major headache – especially when you’re working to tight deadlines. Every component purchased must be carefully checked and recorded with respect to the materials it contains, so that at the end of its useful life it can be disposed of or recycled in the correct manner. This is why so many companies turn to the environmental compliance solution offered by us at �ۿ۴�ý Technologies. We help you collect and manage data relating to the components and parts you buy, so you can comply with REACH regulations.

REACH is an acronym for Registration, Evaluation, Authorization & restriction of Chemicals, an EU regulation which came into force in June 2007. Under this umbrella are a number of other regulations specific to the electronics industry, such as .

RoHS refers to the Restriction of Hazardous Substances Directive, which came into force in July 2006. This places strict, legally enforceable restrictions on the use of 6 hazardous chemicals in electrical and electronic equipment manufacture. The waste Electrical and Electronic Equipment, or WEEE directive, is closely linked to this, but places targets on the collection, recovery and recycling of electronic goods. It’s obvious that with the large dependence placed on manufactured electronics goods today, something must be done to reduce the amount of toxic hazardous waste going into landfills.

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