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REACH notice duty looms over industry

Posted: 16 Oct 2008 ?? ?Print Version ?Bookmark and Share

Keywords:EU REACH program? RoHS? restricted substance?

If complying with RoHS was a nightmare, brace yourself for the European Union's Registration, Evaluation, Authorization and Restriction of Chemicals (REACH) Regulation No. 1907/2006.

In force since June 2007, it is now moving into a phase that will directly impact electronics equipment manufacturers. This month, REACH will require "importers" and manufacturers of "articles" that contain certain "substances" at a concentration level of 0.1 percent or greater by weight to formally notify their customers!typically other OEMs, distributors or retailers!when they deliver the product, and provide safe-use instructions.

Under the new rule, if anyone!and the EU means anyone!asks a manufacturer, local retailer or distributor for information about the restricted substances in the product planned for purchase, the retailer has 45 days to respond. The retailer will call the supplier for the data, causing a chain reaction all the way up the supply chain, according to industry insiders.

In anticipation of the launch of this phase of REACH, non-government organizations such as Greenpeace have published "fill in the blanks" sample letters for people to mail to local retailers.

Like RoHS, many companies find REACH complex and confusing. Terms are not well defined, and information seems incomplete. But unlike RoHS, which deals with six hazardous substances, REACH has the potential to include upward of 1,500 "substances of very high concern" (SVHCs). These are nasty chemicals that are either known carcinogens, are toxic and/or are endocrine disrupters.

REACH is entering a phase that will directly impact electronics equipment manufacturers.

'RoHS on steroids'
The first pass at the initial list of SVHCs was announced in late June and includes 16 substances. These substances will be reviewed and most, if not all, are expected to be approved for the REACH "candidate list" by the European Chemicals Agency (ECHA) this month. The candidate list will undergo a review before being finalized and presented to the EU's Authorization Commission for approval.

"REACH is RoHS on steroids," said Rudolph Overbeek, global director of health and environmental services at Intertek Group plc, a London-based quality and safety services company.

The good news for electronics companies and component manufacturers is that the draft candidate list of SVHCs is mercifully short and most of the 16 substances are typically not found in volume in electronics products. And electronics products, such as TVs and computers, are classified as "articles," which don't need any special labeling.

Starting sixteen
Michael Kirschner, president of consultancy Design Chain Associates LLC, advises electronics companies to review the draft list of SVHCs to see if it applies to their products, as a few of the 16 substances!in particular, three phthalates!are used in some electronics subassemblies.

"It's the mechanical engineers at OEMs who need to be aware of REACH," said Kirschner. "They have to get a better handle on the chemical composition of the connectors, injection-molded plastics and other components they source."

While electronics manufacturers are getting off lightly for now, REACH is expected to become more onerous as the ECHA adds more SVHCs to the list, as often as every six months. "It's death by a thousand cuts," said Kirschner.

Overbeek agrees. "We expect the EU will add 20 or so new SVHCs to the list every year," he said.

Hewlett-Packard Co., for one, is taking the REACH challenge seriously. By the time there are 100 SVHCs on the list, HP will need to collect about 3 billion pieces of data on the chemical composition of their products, estimates Michael Seidel, HP's environmental manager for Europe, the Middle East and Africa.

Perhaps the biggest challenge for HP and others is to create an efficient way to gather and manage this data. "Currently, there is no worldwide standard for communicating this information and no infrastructure in place," said Seidel.

That means OEMs will be asking each supplier to provide data based on their own needs, using their own forms and documents. Suppliers will have to respond to each customer's request in turn. And most will have to gather this data from their own suppliers or their suppliers' suppliers. "It might go down three, four or five levels in the supply base," said Seidel.

Protecting confidential business information is another concern. For some suppliers of components and parts, chemical composition is a closely guarded company secret. Some may be unwilling to provide detailed composition information to their customers or to an EU agency.

HP has founded a REACH roundtable with other large electronics companies to help drive the standards and create structure to streamline data collection and transfer. But this will take time!perhaps years!and standards organizations will need to drive the process for the industry at large.

- Bruce Rayner
EE Times

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