With the REACH Legislation now in its 11th year, CMCA(UK) is finding that much of industry is still unaware of its relevance to it and its subsequent impact. Whilst there are now many component and equipment manufacturers who understand what the legislation means to them, there are equally those who are unaware of it or those who believe it to only be concerned with the chemical industry and as such does not apply to them. Even those who understand their obligations under REACH are then presented with the problems of meeting them and being compliant with the legislation.
So, do you have a problem?
Much of the early focus of REACH was on the chemical industry registering the substances that they either produce or import in the EU at a quantity of > 1 tonne per annum and this process is due to end in May of this year. The evaluation of these substances has led to a list of ‘Substances of very high Concern’ (SVHCs) being created and is known as the Candidate List. The number of these SVHCs currently stands at 181. In addition a second list known as the Authorisation List has been created which details SVHCs that are effectively going to be banned, or in many cases already have been. There are currently 43 entries on this list.
If you are a manufacturer of components or equipment and any of them contain an SVHC in any component part then you have obligations under REACH to inform the recipient depending upon its concentration. In fact, if you are simply just in the supply chain of the product then this obligation also falls upon you when you deliver the product. This means that when producing equipment you need to be aware of whether any COTS items you use contain SVHCs or any of the component parts that you design yourselves.
If you use any of the substances on the Authorisation List then you need to ensure that it hasn’t passed its ‘Sunset Date’ as after that date it will be illegal to use unless you have an authorisation to continue using it in a specific application, or if you have an application for authorisation pending. Whilst historically some of these substances were present in a finished item of equipment, many of them are used in manufacturing processes such as chromate conversions, passivating and anodising. In September 2017 the Sunset Date passed for a number of Hexavalent Chromium compounds which has had a significant impact on industry as these surface treatments and finishes can no longer be undertaken if they utilise any of these compounds. These include Chromium Trioxide, Sodium Dichromate and Potassium Dichromate for example.
How can we help?
CMCA(UK) has a long track record of analysing customer Bills of Material, Items/Parts Lists and engineering drawings to aid with Obsolescence Management, Equipment Data Structure and RoHS Compliance information. Over the last four years we have worked with prime contractors in the defence and aerospace sectors to use our experience to develop REACH Services for them and ensure that they are compliant with the legislation. If you now believe that you may have a problem, CMCA(UK) is here to help.
For more information contact CMCA(UK)’s subject-matter expert on REACH, Glenn Hill on +44(0)1905 458307.