Not even 50% of companies feel that they have good information about the presence of SVHC in their products. That’s the result of an online survey taken as part of the pan-European AskREACH project between June and September 2018. 174 product vendors in 12 EU countries were surveyed, including 67 from France, 50 from Germany, 15 from Sweden, and 12 from Czechia. 60% of the companies that participated in the survey are small and midsize companies with fewer than 250 employees. That number includes companies in the textile, clothing, shoe, accessory, electronic, and household items sectors.
So few companies feel well-informed about the presence of SVHCs because more than 40% of them do not have an IT solution that collects and, if needed, stores data on SVHCs. Yet exactly such a system is required by Article 33, Section 2 of REACH. The article requires companies to respond to consumers within 45 days after they request information about a specific product. The requirement to supply information applies when the concentration of a critical substance is greater than 0.1% by mass.
Almost half of the companies surveyed had already received requests for information from consumers. The French companies stated that they receive an average of 80 such requests each month. Nonetheless, most companies cannot fulfill their legal obligations in this regard because of missing information.
That’s exactly the point of the five-year AskREACH project that started in September 2017. It is coordinated by the German Environment agency (UBA) and involves 20 partner organizations from 13 countries, including governmental agencies, research institutes, and NGOs. The project wants to enable companies to inform consumers about the presence of possible SVHCs when they ask – and do so seamlessly along the entire supply chain.
The scope of the project will include two campaigns to raise awareness among consumers and product vendors across the EU. According to the UBA, the campaigns should begin at the start of this year and cover:
- A reply form that companies can use to respond to consumer requests efficiently according to their obligations under REACH.
- The future ability to upload SVHC information into the European database (under development) and update it if necessary.
- A mechanism to remind companies to update their data when the REACH candidate list is expanded.
- Direct access to product information for consumers to provide relief for the customer service departments of the companies involved.
- The ability for companies to request statistics on database queries anonymously and to view consumer requests.
- An IT tool to simplify the supply of information within the supply chain.
We are familiar with the laws surrounding the use of SVHC. Please contact us at firstname.lastname@example.org.