The graphite maybe is the main ingredient in the 'lead' part of a pencil. The graphite is exempted on registration from Annex IV of REACH. Whereas, EU has published a draft proposal for amending Annexes IV and V of REACH in June 2008.

The substance "Graphite" (CAS: 7782-42-5) should be deleted from Annex IV on the draft proposal. So, if this draft proposal is adopted, the "Graphite" in the 'lead' part of a pencil needs to be registered.

There is no limit on quantity as it relates on import of articles (= products). In principle, all products are covered; the immediate requirement for any supplier of an article into the EU is the following. It is a prerequisite that any client will have information available on SVHC's (there are 15 substances published on the current candidate list, about which I attach an official list) to fulfill the requirements under the REACH regulation. Under Article 33 of REACH Regulation, the supplier of an article has the following responsibilities:

Duty to communicate information on substances in articles:

1. Any supplier of an article containing a substance meeting the criteria in Article 57 and identified in accordance with Article 59(1) in a concentration above 0,1 % weight by weight (w/w) shall provide the recipient of the article with sufficient information, available to the supplier, to allow safe use of the article including, as a minimum, the name of that substance.
2. On request by a consumer any supplier of an article containing a substance meeting the criteria in Article 57 and identified in accordance with Article 59(1) in a concentration above 0,1 % weight by weight (w/w) shall provide the consumer with sufficient information, available to the supplier, to allow safe use of the article including, as a minimum, the name of that substance.
The relevant information shall be provided, free of charge, within 45 days of receipt of the request.

Based on this, any products supplied to a professional user and distributors need automatically to be accompanied, if necessary (=if SVHC present over 0.1% w/w), by SVHC disclosures (Article 33(1)) and safe use instructions. Upon request of a consumer (Article 33(2)), clients will need to disclose the same information within 45 days, but now to a consumer.

ECHA suggest suppliers obtain the chemical information from supply chains and identify the present of the SVHC. The SVHC tests maybe bring high cost and are not the best solution. But 45 days may not be sufficient for suppliers to obtain the chemical information. So, SVHC tests will be a last resort if they cannot gather information from their suppliers.