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The new rule (definition of the "Article"), confirmed by the European court of justice will change ...
- the data we must collect,
- the REACh verdict and other data calculation rules,
- the way we communicate to our customers.
PTC : have you already defined the necessary changes in WPA ? Do you need our help to define the changes ? Will you involve us in the definition of the new version ?
Other WPA users : have you already identified the impacts on your REACh processes and Tools ?
Regards, Pierre.
Not many reactions ! may be should I be more specific ...
It has always been mandatory to communicate REACh data at the "Article" level. And this is still the case ! BUT the "Article" is no longer our product (computer, mobile device, hard drive, head phone, ...) : Each "component" of our product is an "Article" (screw, plastic part, wire, ...).
Have a look to the note on top of this document http://echa.europa.eu/documents/10162/13632/articles_en.pdf
You will also find a link to the judgement.
This will change many things, including the calculation rules (concentration to be evaluated in each component "Article", not in the product), and therefore the REACh report requirements of WPA.
Regards,