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Risk Based Compliance Plan and SVHC Testing

Simple Solutions to Complex Chemical Management Challenges

Business Challenge

Under Europe’s REACH Regulation, all Europeans are given the right to obtain information on the presence of dangerous chemicals, or Substances of Very High Concern (SVHC), in articles or preparations at quantities greater than 1000mg per kg or 0.1%w/w in everyday consumer product they purchase.

Retailers, brands and manufacturers have only 45 days to answer what substances are in their products. The timeliness and quality of a company’s response to the REACH obligations is being closely watched by non-government organizations (NGOs), consumer groups and the media. Companies will need to be prepared to meet this requirement under the candidate list published by the European Chemicals Agency (ECHA).

Your company may be dealing with tens, hundreds or even thousands of products and suppliers without the time and resources to collect the necessary information on all of them. So, where to start? Is there a way to facilitate the process and focus on the highest risk products? How best to validate the absence of SVHC?

Solution

It is difficult to provide Bill-of-Materials (BOM) and Bill-of-Substances (BOS) for all products. Also, time is limited and labour costs can easily spiral as a result of compiling the necessary information to fulfill your chemical management obligations. In view of this, Bureau Veritas’ professionals can help by providing a Risk Assessment solution to initially identify your highest risk product categories and suppliers. This will allow the allocation of resources to perform SVHC testing on the highest risk products first. The plan also provides guidance on how best to manage procurement on a category and supplier level to maintain chemical compliance in your target markets.

OUR APPROACH

Based on market needs, Bureau Verita s has developed risk profiling and two- tiered SVHC testing solutions. Both test services are used for mitigating the risk of having unknown SVHC. This testing is imperative for fast moving consumer products such as textiles, g arments, home accessories, seasonal items and recycled products. The service can also apply to situations where insufficient information on substances exists due to the lack of a Bill-of- Substances (BOS) or nature of the product.

Risk Profiling
• Identifies greatest risk items and allows you to best allocate your Quality Assurance (QA) resources and expenses. Criteria is based on:
   o economic indicators (volumes, core range items)
   o brand equity (e.g., private labels, promotional items)
   o NGO focus chemicals (e.g., phthalates, artificial musk, heavy metals)
   o products with high risk user and exposure profiles (eg, juvenile products, food contact) and
   o substances intended to be released from articles (eg, candles, crayons, scented products, cleaning wipes.)
• Keeps you focused on the high risk areas.
• Enables you to document and demonstrate that your actions are in line with the principles of your target market’s chemical regulation, including the precautionary principle under the EU REACH Regulation.
• Translates uncertainty into an actionable roadmap with monthly plan.

Brand Protection and Risk Management: Bureau Veritas SVHC Test
• This test is designed to detect SVHC in different material categories and is available for articles only.
• Focused on all known and detectable SVHC as listed in, ECHA Candidate list proposal for Annex XIV, October 08 – REACH, and CMR’s listed in 67/548/EEC and 76/769/EEC.
• Tests for broad range of SVHC (800+ substances).
• A proactive approach to managing hazardous substances regarded as Carcinogenic, Mutagenic or Toxic to Reproduction (CMRs).

Compliance with Mandatory SVHC REACH Requirements: Annex XIV / ECHA Candidate Test
• This test is designed and limited, to detect SVHC as published in Annex XIV / the Candidate list published by European Chemicals Agency (ECHA) concerning REACH Regulation.
• Available for articles, cosmetics, and preparations (consumer products).

Why Choose Bureau Veritas?

• Our Risk Assessment solution enables you to allocate your resources toward the highest risk product categories, suppliers and users.
• Our approach identifies the root source of SVHC, providing time for corrective actions in reducing, eliminating or substituting the SVHC.
• “Testing up front” provides a means for you to meet your 45-day obligation under Europe’s REACH Regulation by validating the absence of SVHC below the applicable thresholds.
• For convenient access, Bureau Veritas has laboratories to assist you worldwide, in America, Europe and Asia.

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