According to the European court of justice decision, the threshold should not be considered at the product level but at the article (component) level. As product manufacturers, we must communicate where the concerned substances are located in our products and what are the instructions for safe use.
-> How can we record these new sets of data at the parts level (data received from our suppliers) ?
-> How can we report this set of data at our products level (in BOM reports) ?
I agree with your post, but this also puts more pressure on manufacturers to watch the undefined portion of the substances: those substances that are "misc. not to be declared" or dash CAS substances. I suspect that PTC took advantage of the relationship of the masses: an undefined substance (anything without a CAS#) that is a portion of a component that weighs a few grams is not significant in an article (the assembly) that weighs several kilograms. But with the basis being the individual purchased components, a component with 10% undefined mass can be an issue. WPA does not highlight undefined substances, and there are not many tools for managing them.