The countries France, Belgium, Denmark, Germany, Sweden and Norway have published a guidance document  “Guidance for Suppliers of Articles”   that explains SVHC communication responsibilities based on the “Once an article, always an article” principle.  These countries have previously disagreed with the ECHA guidance that allows the 0.1% threshold to be applied based on the weight of the imported article.  The guidance document advocates a reporting threshold for SVHCs that is based on when substances/mixtures containing an SVHC are first made into an article.  According to the guidance, the information on SVHC content must be provided to downstream manufacturers and users even if the the first article (usually a part) is assembled into a larger article.   This principle will have a significant impact on the restricted substance control systems for many EEE manufacturers and distributors.