Identification of Substances of Very High Concern
A Roadmap for Industry
► Key steps
Keep in mind that the identification of a relevant SVHC logically leads to prioritisation and then Authorisation, or in some cases a Restriction that may be a total ban.
The earlier planning starts, the more time there is to weigh the pros and cons of the different options, including calculating their financial implications. Preparing an Application for Authorisation is costly and introducing such a dossier is also expensive as there are fees to pay to ECHA per use applied for. Simulating the costs of the different options available to the company as far as the use of the substance is concerned can quickly indicate what the best business case is.
When estimating the burden on your company in preparing ultimately for Authorisation it is important to have a clear view of its place in the supply chain and to consider the likely responses of the other actors. Could there be a disruption of supplies? Might prices go up? Could segments of the chain opt for production outside the EU? Will the end users insist on substitution? Could your company be covered by an application lodged by a manufacturer or upstream supplier? Could your use of the substance, when properly defined, be considered for exemption?
Metal producers are in the particular position that they are tied to a substance that is not the product of a chemical synthesis and with intrinsic properties that cannot be modified.