Background on REACH and Updates in 2022

Background on REACH

Created by the European Union (EU), REACH regulates the Registration, Evaluation, Authorisation, and restriction of Chemicals. The goal of REACH is to limit the potential risks chemical substances impose on both human health and the environment. REACH is enforced by the European Chemicals Agency (ECHA). The ECHA manages the technical, administrative, and scientific aspects of REACH.

The Impact of REACH on Electronics

Thousands of chemicals used in electronic components are affected by REACH guidelines. End products and substance mixtures or solutions are also reviewed under REACH policies. REACH identifies Substances of Very High Concern (SVHC), which are the most hazardous and highly regulated substances involved in manufacturing. SVHCs are difficult to authorize, especially if a safer alternative exists.

When you get a moment, scan the candidate list for SVHCs at the official ECHA website. You may find a chemical used in one of your products violates REACH. This could lead to a disruption in your company’s supply chain.

However, you may not know what chemicals are used in your products. In that case, you will need to gather information about the chemicals in your products first. Contact your suppliers for full-disclosure substance data to ensure you are not receiving any components containing substances that violate REACH.

If you cannot access full-disclosure substance data, at least request a non-use SVHC statement. Suppliers should notify you when SVHC concentration exceeds 0.1% in concentration. However, the reality of the situation is your company remains at risk if it relies on its suppliers for notification.

Necessary documentation is essential, as companies are required to submit registered dossiers to the ECHA. These registered dossiers inform the ECHA that the sum of all electronic components produced or sold does not exceed the limits imposed by REACH.

REACH Regulation Expansion in 2020 & 2021

Data requirements were increased in 2020 due to several new REACH regulations. In 2020, companies were required to disclose more information about nanomaterials.

Nanomaterials are, according to the ECHA, “chemical substances or materials with particle sizes between 1 to 100 nanometers in at least one dimension.” Electronic companies with products containing nanomaterials are affected by the new REACH regulations. For example, various batteries on the European market contain nanomaterials, which will now need to be registered and evaluated by the ECHA.

Now in 2021, there are currently 219 substances on the SVHC Candidate List. The new substances added to REACH in 2021 are often used in plastics manufacturing, solvents, and flame retardants.

Here is a breakdown of how the banned substances pose harmful risks:

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Of the 219 hazardous substances, nearly 67% are considered carcinogenic, mutagenic, or toxic to reproduction. This is significant for the electronics industry because electronic components and products such as batteries, liquid crystal displays (LCDs), circuit boards, etc., contain potentially carcinogenic substances like azo dyes, cadmium, and nickel—to name a few.

With this correlation, it’s important for electronic companies to pay close attention to the chemicals in their components, or they may fall into one of the categories below.

REACH Updates for 2022

The EU Commission is prepping for a partial revision of REACH in 2022. The partial revision will be a continued focus on SVHC, polymers, mixtures, and simplifying restriction and authorization processes.

The six, primary regulatory matters that are expected to be implemented in the 2022 revision of REACH are as follows:

• Waste, SVHC, and recovered substances
• Combined exposure
• Polymers/Polymers of concern
• Endocrine Disrupting Substances (EDS)
• Chemical substances and environmental effects
• Dossier quality update and upkeep

Avoid the 8 and 30 Percent

A study in 2013 revealed that 67% of companies fail to comply with ECHA chemical regulations. Of the 67% of companies, 8% failed to comply with REACH regulations. This means 94 out of 1,181 companies did not meet the requirements of REACH. Electronic companies don’t want to fall into that minority, as failing to comply with regulations can lead not only to supply chain disruptions but can also harm the reputation of a company.

Despite that, 30% of companies believe REACH does not affect them. Such companies believe REACH only affects chemical manufacturers. However, as explained above, REACH applies to companies involved with any electrical appliances or components that contain potentially hazardous chemical substances.

Any electronic company should avoid falling into the 8% and 30% of companies that either fail to comply with REACH or simply believe they are unaffected by its guidelines. To avoid this, follow the steps of REACH:

• Register: Any company dealing with substances in quantities of one ton per year or more needs to register with the ECHA by preparing a technical dossier and a chemical safety report.
• Evaluate: Once dossiers and reports are submitted, the ECHA will evaluate any potential risks or hazards.
• Authorize: Companies with SVHCs that are not authorized must submit plans to replace the substances with safer alternatives.
• Restrict Chemicals: Any chemical substances deemed unsafe may be restricted by the EU.

Remember:

Consistently communicate with suppliers and manufacturers and continue reviewing updates to REACH policies. Disruptions in the supply chain can lead to weeks of loss. Complying with REACH regulations allows an electronic company to mitigate potential supply chain lapses and profit losses.