If you thought complying with RoHS was a nightmare, brace yourself for REACH.
The European Union's Registration, Evaluation, Authorization and Restriction of Chemicals Regulation No. 1907/ 2006 has been in force since June 2007, but it is moving into a phase that will directly impact electronics equipment manufacturers. Starting in late October, 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 October launch of this phase of REACH, nongovernment 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." These SVHCs, as they are called, are nasty chemicals that are either known carcinogens, are toxic and/or are endocrine disrupters.
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) in late October. The candidate list will undergo a review before being finalized next summer and presented to the EU's Authorization Commission for approval.
