Identification of Substances of Very High Concern
A Roadmap for Industry
► Key steps
Industry will first have to mobilise its resources and each company will have to assess its exposure to issues related to the identification of relevant SVHCs. This internal assessment already allows the identification of possible options for the company and where there needs to be action involving other actors in the value chain. A significant communication effort may then have to be envisaged to ensure that the entire value chain, including users of articles is made aware of the possible challenges ahead. All actors will have to act and contribute data and other resources to the Risk Management Options analysis (RMOA) that ECHA or a national competent authority will perform. The trade associations or consortia could be good vehicles for such communication.
If the Industry cannot convince the competent authorities that the substance should not be considered as a relevant SVHC, it will have to start anticipating future steps. These will include the building, if possible, of a convincing case that the substance should not be prioritised and/or set up the structures and procedures to act on a prioritisation.
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