REACH introduces a wide range of requirements on component suppliers and equipment manufacturers.
In particular, REACH introduces new requirements on all suppliers in the supply chain (components, sub-assemblies, finished equipment etc) to
- Provide declarations for substances of very high concern (SVHC) on the REACH Candidate List from October 2008 (Article 33)
- Comply with substance restrictions from June 2009 (Article 67)
REACH is fundamentally different to RoHS because under REACH all EU suppliers have a direct legal obligation to provide information on the REACH compliance status of their components, sub-assemblies, finished equipment etc.
New REACH substance declaration requirements every 6 months
Starting from August 2009 the REACH Candidate List of Substances of Very High Concern (SVHC) will be updated every six months. A draft list will be published in February and August each year and the European Chemicals Agency intends to add about 25 substances per year to the list. The declaration requirements start immediately that the new list is published. The European Chemicals Agency (ECHA) Guidance on Requirements for Substances in Articles notes that component suppliers and equipment manufacturers who supply to businesses are required to inform their customers “automatically i.e. directly after the substance is included in the Candidate List”. For products supplied to households, the manufacturer must provide substance declarations within 45 days of request.
The ECHA Guidance also notes that
Supply chain communication is the most important and effective way of gathering the information needed to identify compliance obligations under REACH. In this regard, establishing communication standards for the supply chain is an important task for the private sector in order to facilitate the implementation of REACH.
BOMcheck provides this communication standard.
Philips has decided not to receive REACH compliance information individually from each of our suppliers each time a new list is published” said Jan-Willem Scheijgrond, Senior Director Environment, Health & Safety at Philips Corporate. “Instead, we require all of our suppliers to comply with these REACH obligations by joining BOMcheck - the centralised, open-access substances declarations web database.
Need for expert guidance on SVHC substances in the supply chain
One of the biggest issues that component suppliers face is accessing expert knowledge on where these substances of very high concern are found in the supply chain. For example, many suppliers have focussed their attention on flexible PVC as the most likely source of the DEHP and DBP reprotoxic substances in their products. However, DEHP and DBP are also found in nitrile butadiene rubber (NBR) which is commonly used in many household and industrial products. Recent samples of NBR components manufactured in China and Taiwan have found concentrations of DEHP and DBP of up to 20% w/w.