The European Union’s REACH (Registration, Evaluation and Authorization of Chemicals) Regulation mandates all manufacturers of articles communicate the presence of SVHCs (Substances of Very High Concern) which they sell in the European Union.
Companies selling in Europe are frequently purchasing products from non-EU markets and rely on their non-EU suppliers to support their information requirements. One of the new information requirements now under REACH is knowledge related to SVHCs.
Without the following information about SVHCs, companies who sell in Europe cannot be REACH compliant.
Requirement No. 1
Manufacturers must know about the presence of any SVHC greater than 0.1% concentration in their exported articles. The new reality under REACH is that it is no longer acceptable to not know what substances are in your articles. In particular, for any article manufactured outside of the EU, there is a strong likelihood the customer is going to be asking for the supplier to identify the presence of any SVHCs which are present in amounts greater than 0.1 weight %. This percentage is to be evaluated on the basis of the weight of the total amount of SVHC in the article divided by the weight of the entire article.
Requirement No. 2
Manufacturers must follow the development of the SVHC List as it evolves over time
As of the publication of this article there were 15 SVHCs and the European Chemicals Agency had plans to add an additional 7 SVHCs in the near future. The shifting nature of the SVHC list means that manufacturers are required to educate themselves on the additions to the list which will be frequent.
Requirement No. 3
Manufacturers must include information about safe use for their articles. Under REACH, an article containing an SVHC must now be furnished with safe use information that describes how to avoid being exposed to risks associated with the SVHCs. This new requirement is analogous to the requirement that currently exists for substances and mixtures – the need to supply Material Safety Data Sheets (MSDS).
SEE ALSO
Custom research and briefings
REACH has changed the compliance landscape now so that something similar to a “MSDS for articles” is now required whereas no such information had been required in the past for articles, even if they contained dangerous substances.
Requirement No. 4
Manufacturers must be prepared to answer consumers’ questions about SVHCs within 45 days of a consumer request for information. In Europe, under REACH a consumer has the right to ask for information about the presence of an SVHC in any product! That consumer is entitled to receive a response from any European company within 45 days addressing the presence of SVHC in the article and advising on safe use information, as per requirements 1 and 3 above.
This short amount of time can make it very challenging for information to be transferred through the supply chain quickly enough for a company to remain compliant.
Requirement No. 5
Manufacturers must go to their own suppliers and ask them for all of the SVHC and safe use information that is lacking. Manufacturers of electronics assemblies will normally be purchasing sub-assembly articles as components for their own final assemblies. In this scenario, there are likely to be gaps in the knowledge about potential SVHCs in the purchased sub-assemblies.
It will be necessary for electronics manufacturers to solicit information from their suppliers to fill these data gaps. Part of that effort may involve providing resources, direction and training to those suppliers in order to assist them in fulfilling the information request.
Summary
REACH has necessitated a tremendous increase on the information requirements for suppliers of articles.
Now SVHC information and safe use recommendations must accompany product shipments as they flow through the European Union. As a result of this need, non-EU manufacturers who supply EU companies will need to collect and report SVHC information to their customers in order to ensure those customers can successfully comply with REACH.
The 45-day limit on providing a response to a consumer solicitation presents serious challenges for companies doing business in Europe since they have to dig this information out of their supply chains. This new requirement will affect companies in Europe and their suppliers outside of Europe in very significant ways by requiring new processes for data collection, data management and data reporting for SVHCs.
VentureOutsource.com, November 2008
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