European Court of Justice about Art. 33 REACH-VO
2018-12-15
In his judgment of 10 September 2015, the European Court of Justice ruled that Articles 7 and 33 of the REACH regulation should be interpreted with the guideline “Once an article always an article”. This means, for example, that the concentration limit of 0.1 mass-% in Article 33 REACH Regulation for an article (=product) consisting of components applies to these components and not to the entire product (Case C 106/14). In the discussion with government industry associations of the sectors concerned, particularly the car industry, did not find yet a way how to limit complexity and workload of the new interpretation of Articles 7 and 33 REACH regulation. Guiding question: how to deal with the multilayer vertical integration?