DCA's PTER Services
General RoHS and Substance Restriction Services
REACH is a new European Union regulation that effectively hands the chemical industry and their customers' supply chains responsibility for proving that otherwise grandfathered substances are safe and can be handled and managed safely throughout their entire lifecycle. Previously, since the US first developed the chemicals policy defined by the Toxic Substance Control Act in 1976, government has had the responsibility to prove that grandfathered chemicals in commerce were unsafe. TSCA has suceeded in banning only five such substances (and the asbestos ban was overturned). The EU has determined that this form of chemical policy is failing to protect users, consumers, and the general public and thus REACH.
Electronic products (and all "articles") are generally exempt from most aspects of REACH, except in certain instances, which include:
While it's not immediately obvious that there are many electronic products that meet the definition of intentionally releasing substances, it is a requirement that substances that are intentionally released from articles and are present in the articles in an amount greater than one metric ton per year be registered.
Producers selling articles that contain candidate SVHCs over 0.1% by weight and are present in quantities greater than one metric ton per year may, under certain circumstances, have to notify the European Chemicals Agency.
Customer DisclosureYou will need to disclose any candidate SVHCs that are in your product above 0.1% by weight to your customer, and provide adequate safe use information to them. If any consumer asks, you will need to similarly disclose the presence of any candidate SVHCs in your product above 0.1% by weight, and provide adequate safe use information to them. "Consumer" is not defined by the regulation, but essentially means anybody. Perhaps the most onerous challenge of REACH, however, is the risk that one or more of your suppliers either is unaware of REACH and could be caught up in an enforcement action that shuts down your product line, or they are planning to discontinue a substance or preparation that could require you to find another supplier or redesign your product. Awareness of REACH throughout the electronics supply chain is quite low right now (only a few industry segments are on top of it), and if you think back about what happened with RoHS you will want to make sure that your supply base knows about this regulation, its impacts, and is preparing for it.
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DCA has extensive experience training and helping electronics and manufacturing clients, including OEMs, PCB manufacturers, and component manufacturers, determine their responsibilities and business risks under REACH, as well as tracking and interpreting the ongoing implementation of REACH for them. We have excellent contacts in the European Commission, industry organizations, standards bodies, universities, as well as with NGOs that broaden our insights in to regulatory issues, industry approaches, and consumer concerns. Contact us today to learn more about how DCA can help you prepare for REACH.
