image de fond
REACH Authorisation
made simple
go to  the twitter account go to  the linkedin account

Identification of Substances of Very High Concern

A Roadmap for Industry

► Key steps

4. Anticipation

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.

Do consider the pros and cons of anticipative action.

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.

Do simulate costs for all options at hand.
Do consider how your supply chain is structured and the roles and interests of the actors involved. It may save you precious time later and will help to keep expectations realistic.

The materials and information included in this publication are provided
as a service to you and do not necessarily reflect endorsement by the
Nickel Institute. The Nickel Institute is not responsible for the accuracy
of information provided from outside sources.
Users are advised to seek their own professional advice.