Providing candidate list substance declarations from October 2008

In addition to obligations on suppliers, REACH Article 33 also places obligations on manufacturers to inform their customers whether the assembled product contains more than 0.1% w/w of any Candidate List substance.

If the customer is an industrial or professional user, or a distributor, then Article 33 (1) requires the manufacturer to provide this information when they supply their products.

If the customer is a consumer (e.g. a private individual, household user etc) then under Article 33 (2) the manufacturer is required to provide this information free-of-charge within 45 days of receiving a request from any consumer.

To prepare for this REACH requirement, all EU manufacturers should insist that their EU suppliers comply with their legal obligations under Article 33 (1) to inform them whether the components and sub-assemblies they supply contain Candidate List substances.

BOMcheck gathers the weights of the suppliers' parts and the actual percentage composition of Candidate List substances in the parts.  The manufacturer can use BOMcheck to calculate whether a Bill of Materials (a structured list of part numbers) for a particular product exceeds the 0.1% threshold for any Candidate List substance.  No manufacturer product data is stored on BOMcheck.  The manufacturer’s list of part numbers is automatically deleted after the calculations have been completed on BOMcheck.

For further information, please contact Dr Aidan Turnbull
Head of WEEE, RoHS & EcoDesign on +44 (0)1225 748420