Some people think they can treat REACH like they do RoHS and just get a certificate that a chemical or product is “REACH Compliant.” RoHS (EU Restrictions of Hazardous Substances) limits the levels of only 6 substances in specified products (Pb, Cd, Hg, CrVI, PBB, PBDE). If you get a composition certificate, you're free to market. REACH (Registration, Evaluation, Authorization and Restriction of Chemicals), on the other hand, is a whole different beast that affects nearly all products and members of a supply chain.
Sure, you can get information from your suppliers that their chemical(s)have been registered for REACH, but that is only one of the requirements that applies to the supply chain. Did they register your product's uses and volumes? Have they told you about the presence of Substances of Very High Concern (SVHC) - a list that grows every 6 months - so that information can be passed downstream (even for imported articles)? SVHC requirements are in addition to registration and can involve restrictions if the SVHC make the authorization list. Plus, everyone in the supply chain must prepare and follow the safe use conditions in new versions of Safety Data Sheets (that comply with REACH and the Classification, Labeling and Packaging Regulation). Add to that new action by ECHA to "evaluate" registered chemicals for potential additional risk management measures. Furthermore, REACH requirements keep on coming as the registration itself needs to be updated to include new volumes, uses and toxicity information.
(Whatever you do, don't assume you are "REACH compliant" just because you can find your chemical components on the ECHA registration list. Your supplier has to have registered your uses.)
REACH is exceedingly complicated. It makes RoHS look like a picnic. I heard a recent estimate that there are now over 28,000 pages of REACH guidance issued by ECHA.
So if someone tells you not to worry, his product is "REACH compliant" - dig deeper on what he means and what that means for you and your customers.
EHS Strategies, Inc. can help work through your REACH obligations.
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- REACH