No, it is not. Under the EU regulations on SVHC, it is the responsibility of enterprises to identify and prove that their products are fully compliant with the terms and conditions set in the regulations. In the end, enterprises should be able to provide sufficient justifications.  Justifications can be in the forms of test results, facts and figures from scientific research, and expert judgment based on all available data related to the products, literature, read-across approach, etc.  Testing is a reliable and strong method to qualitatively and quantitatively identify SVHC in the article. During the assessment, the competent authorities may request enterprises to provide test results if other justifications are not sufficient to confirm compliance.  Hence, if test data is not available and the project’s schedule is favorable, it would be good to assess all other data from the enterprises and from the published literature which are relevant to the product. Based on that, the testing step can be considered.