In addition to registration, you should also be concerned about the development direction of REACH after 2018. With the development of EU REACH after 2018, the European Chemicals Agency (ECHA) will require operators to maintain registration updates, and will continue to conduct substance assessment and inquiry, authorization and restriction, and implement CLP Audit work such as specifications and safety data sheets. As a finished product supplier, you may be faced with finished product registration, notification or supply chain communication obligations. In July 2013, REACH enforcement agencies (including Belgium, Denmark, France, Germany, Norway, and Sweden) announced the compliance guidelines for substances of high concern in finished products (Guidance for Suppliers of Articles). In terms of supply chain communication, it is recommended that if the finished product contains SVHC > 0.1% (w/w), the industry should provide consistent information whether it is a separately sold finished product or an assembled finished product. And if the assembled finished product contains SVHC, the information content should include where the SVHC substance is contained, and the information should be communicated concisely among the supply chain. It is worth noting that on September 10, 2015, the European Court of Justice ruled that individual finished parts should be used as the basis for calculating SVHC 0.1% (W/W). Taking shirts as an example, the SVHC content of the shirt's textile fabric, buttons, and sewing threads will be calculated separately, instead of using a single shirt as the calculation unit. In order to comply with the requirements for information communication between REACH supply chains, it is recommended that enterprises analyze the information provided by suppliers and grasp the following principles:
