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In September 2015, a press release, based on a judgment by the Court of Justice of the European Union (CJEU) was published. It stated that, under REACH, 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 present in an isolated manner – the once an article, always an article approach. The CJEU ruled that the duties to notify (Article 7(2)) and provide information (Article 33) for an article containing an SVHC in a concentration of more than 0.1% apply to each article incorporated as a component in a complex product.

As an independent third party provider, we are committed to following the interpretation of the legal framework as clarified by the CJEU. To clarify our stance, we have prepared a position statement outlining our approach to SVHC related services, in line with the CJEU rule.

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