The REACH regulations entered force throughout the European Union on the 1 June 2007. They represent the most significant upheaval to the regulatory environment for chemicals in over 25 years. REACH applies not only to chemical manufacturers and importers, but also has major implications for manufacturers and importers of electrical components and equipment. ERA is providing consultancy on all aspects of REACH from identification of the implications and obligations, to full audits of substances used in production and planning of business strategy.

REACH - a brief guide

What is REACH?
Only 3% of the chemicals used by industry are fully tested for their effect on health and the environment and an alarming 20% have no data at all. REACH aims to resolve this lack of data by ensuring that all chemicals are thoroughly tested. About 30,000 existing chemicals will be subject to much rigorous assessment, as will all new chemicals. REACH is not only affecting chemical manufacturers and importers but also imposes new obligations on manufacturers of electrical components and equipment, importers and distributors.

Who will REACH affect? Although chemical manufacturers and importers will certainly shoulder much of the burden, REACH is based on the principle of producer responsibility. This responsibility extends to all parts of the supply chain including:
	manufacturers of products (known as "articles" by REACH) - components, sub-assemblies, finished products
	users of chemicals (known as “downstream users”) – chemicals include solvents, adhesives, coatings, alloys, etc.
	distributors
	importers of articles (products) and of chemicals.

REACH affects the manufacture of all types of products sold, made, imported or used in the EU. Many of the 30,000 chemicals affected are used in electrical and engineering products.
It is inevitable that almost all of the electronics supply chain will be affected to some extent and there are already legal obligations in force.

What obligations apply to electrical producers and their supply chain?
REACH will affect equipment producers in many ways:

• Manufacturers and distributors who import materials into EU may need to register these.
• Customers will need to be informed if Substances of Very High Concern (SVHCs) are present in any item supplied. This includes accessories and spares. There is no lower weight limit for SVHC.
• The first SVHC candidate list has been published and suppliers are obliged to inform their business customers if their products contain any of the 15 SVHCs at >0.1% in an item.
• There will be authorisation requirements for using some SVHCs and the ECHA has published a list of seven that it is proposing to include in Annex XIV (substances that will require authorisation).
• "Exposure Scenarios" describe how substances can be safely used. Suppliers will be appending these to safety data sheets and if your "uses" are not included, you could have only 12 months to change your production processes to comply. Manufacturers should inform their suppliers of how they use chemicals to ensure that these "uses" are covered.
• New format safety data sheets are being generated and manufacturers will have new obligations from these.
• The most hazardous substances could be withdrawn by suppliers or be subject to restrictions in the future (this is already happening). The EU body that enforces REACH has advised manufacturers to audit the materials they use as soon as possible. It will be prudent to avoid using the most hazardous substances in new product designs and to be prepared to find alternatives if suppliers are planning to withdraw materials.

All suppliers need to take action now and plan to provide information to customers so as to avoid future disruption of their business. Some chemicals have already been withdrawn and more will follow. The EC estimates that there will be over 2000 SVHCs all of which will have information obligations and restrictions may be imposed in the future.

The diagram below summarises the timeline for the registration of substances. Although it stretches out to 2018, there are already some niche materials being removed from the market. The first list of SVHCs has been published and more will be added to the list in the future.

Timescale for substances produced/ imported per manufacturer or importer in volumes specified in tonnes per annum

CMR = carcinogen, mutagenic, reproductive toxin
Environmental toxins – substances defined as “very toxic to aquatic organisms”

ERA's REACH consultancy services
ERA understands the complex REACH requirements and can provide consultancy on:

• How REACH applies specifically to the electrical product sector including equipment manufacturers.
• Where and how chemicals are used in products and which are hazardous, what is likely to be restricted, what requirements could arise as a result.

ERA can also help to answer questions and help formulate action plans to minimise disruption and business risk.

ERA can help in the following ways:

Consultancy
• Strategic planning to identify the gaps between the requirements of REACH and a company's present position
• Collating data and help draw up plans to attain compliance and avoid disruption
• Preparing documentation (e.g. letters to suppliers, customers, SVHC information, etc.) to support this
• Auditing chemicals and materials currently used to identify those that may be withdrawn or subject to restrictions in the future in order to avoid future disruption and minimise costs
• Reviewing internal audits of materials to ensure that all of the REACH implications have been considered
• Consulting on all aspects of REACH.

Training and Information
• Public training courses from ERA and industry experts
• Tailored in-house training courses
• ERA's bimonthly newsletter RE4view covering all environmental regulation worldwide pertaining to the electrical products sector including REACH.

All of these can be provided on an individual or call-off contract basis or through our subscriber scheme, AccessERA.

ERA’s credentials
ERA’s reliability and failure analysis group (RFA) has been helping industry solve product related problems for over 40 years. Over this period ERA has developed extensive knowledge of component and sub system design, materials and processing. ERA is a also a longstanding provider of regulatory compliance support (e.g. EMC and safety) and, together, these two capabilities have enabled us to help industry, government and the European Commission with many technical aspects of environmental regulation related to the use of materials in products. Initially this was applied to restricted substances (RoHS Directive) and end-of-life (WEEE Directive) but now extends to the growing field of substance restrictions and environmental requirements such as REACH, eco-design (EuP Directive) and similar developments worldwide.