Think you are out of REACH? – Think again
11 August 2008
Colin Martin looks at how REACH is of concern to the whole electronics manufacturing supply chain.
The Registration, Evaluation and Authorisation of Chemicals Regulation (EC No. 1907/2006) known as REACH is an all-encompassing European Regulation that will affect the manufacture, use and disposal of chemicals in Europe.
It is an EU Regulation and does not require implementation in individual Member State’s legislation as it is directly enforceable. REACh entered into force on 1 June 2007 and its aim is “to streamline and improve the former legislative framework on chemicals of the EU. REACH places greater responsibility on industry to manage the risks that chemicals may pose to the health and the environment.” This is a quote taken from the new European Chemicals Agency website .
Many companies are aware that the main targets of REACH are the manufacturers and importers of chemicals, and it is true that they will bear the major burden of compliance duties in terms of registering their products.
However, Article 33 of the 849-page REACH Regulation requires that the composition of articles (i.e. manufactured items) is passed down the supply chain, with particular emphasis on substances contained in articles that have particular hazardous properties. These are the so-called ‘substances of very high concern (SVHC)’, that have significant toxic properties, either to human life or the wider environment. A range of substances fall into one or other of these categories and many of them are contained in PCBs and components. Examples are organic chemicals in solder resist, some epoxy resins and heavy metals.
This requirement under Article 33 is most likely to manifest itself in the form of questionnaires from OEMs to their suppliers, asking if the products supplied contain SVHC. At present these are defined as carcinogens, mutagens or reprotoxic substances (CMRs), substances that are Persistent, Bioaccumulative and Toxic (PBTs), or substances that are very Persistent and very Bioaccumulative (vPvBs).
In order to supply this information, a manufacturer of articles will need to know every substance contained in every consumable in their factory. This includes process chemicals, plastics, laminate and components. Having identified the CMRs, PBTs and vPvBs in the finished products, their percentage composition will need to be calculated, and certain disclosure requirements exist if the concentration is greater than 0.1% w/w.
If a manufacturer of articles is asked for this information, he has 45 days to comply with the request and with many questionnaires from major OEMs already in circulation, it is advisable to start sooner rather than later.
Colin Martin is a Partner in Paragon Chartered Chemists; a company that provides advice and auditing services for users of industrial chemicals.
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