As users must apply exemptions appropriate to application or use, we feel the generic naming and grouping of WPA 10.1 REACH Restricted exemptions without any indication of use is highly problematic. Historically, exemptions have contained key words and usage information so the EDM is not required to remember hundreds of pages of specifications and their allowable usage. E.g. “Used according to REACH Restricted Directive…”
We feel that clear definitions such as “RR51 – Not used in toys or childcare articles”, is a good example of the type of definition which should be supplied.
Note - this may require more enumerations for some exemptions, such as RR47a and RR47b below.
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