In September of 2015, the European Court of Justice (ECJ) ruled that the original definition of an ‘Article’ stands true, meaning “Once an Article, Always an Article.” The new guidance document on defining and determining substances in articles under REACH from the ECHA is having a major impact on both the supply chain and OEMs of products. In our recent webinar, TÜV Rheinland discussed the impact, how to define articles, and how using a risk-based approach is the best path forward to demonstrate compliance.
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Background on the Pilot Project
Currently, it can be quite difficult to determine the level of compliance on suppliers of articles. As a result, the Forum for Exchange of Information on Enforcement has started a pilot project to help negate this issue. The purpose of this pilot project is to raise the awareness of the legal obligations for importers, subsequently raising the level of compliance among producers under Articles 7 and 33 of the REACH regulation. This project aims to target the reasons for non-compliance and inevitably establish better enforcement methods in the future. The operational phase of the project began in October 2017 and will run until the end of June 2018. A report of the results is expected by the end of November 2018.