REACH on environmental laws – Electronic products and technologiesElectronic products and technologies

You may have heard of the famous Restrictions of Hazardous Substances in Electrical and Electronic Equipment (RoHS). The REACH regulation is another European environmental law that directly impacts producers and importers. Every six months, the European Union (EU) lists substances of very high concern (SVHC) under REACH. We will briefly introduce the applicable REACH requirements and the latest list of the 223 REACH SVHCs.

What is EU REACH?

First, let’s summarize the REACH Regulation. Within the European Union (EU), all manufacturers, importers and downstream users must comply with this law known as the Registration, evaluation, authorization and restriction of chemicals regulation 1907/2006. According to the European Chemicals Agency (ECHA), this regulation aims to “improve the protection of human health and the environment against the risks that chemicals can pose, while strengthening the competitiveness of the EU chemical industry”. The requirements in question include hazardous substances commonly used in electronics, such as medium-chain chlorinated paraffins (MCCPs) in plastics. Applicable to article producers (i.e. physical products), we can find REACH restrictions under Annex XVII) and SVHC reporting obligations.

Annex XVII of REACH

The REACH regulation includes Annex XVII, with restrictions on pure substances in various applications. Few of these conditions have a direct impact on electronic devices, such as nickel and compounds that are not permitted when intended to come into direct and prolonged contact with the skin. For example, a knob, handle, or sight may have prohibited nickel finishes. It is important to note that amendments regularly add new restrictions to Annex XVII.

The REACH SVHC list

The SVHC list is another crucial inventory of hazardous materials that companies need to monitor. Indeed, some SVHCs are considered carcinogenic, mutagenic or toxic for reproduction (CMR). Other SVHCs can cause environmental damage by being persistent, bioaccumulative and toxic (PBT).

Therefore, if a component of an electronic assembly contains an SVHC at a concentration of 0.1% or more (w/w), producers must notify downstream users. To this end, customers have the right to ask a supplier whether a product contains SVHCs.

SVHCs in electronics

Undoubtedly, the SVHC list strongly impacts the electronics sector. For example, you can find in this table some SVHC present in electronic applications:

Table 1

223 SVHCs

Every six months, the SVHC list contains new chemicals. Therefore, since January 17, 2022, four new high-risk substances have been added to the list of SVHCs. Therefore, there are now 223 SVHC entries. Here are the four new additional SVHCs:

  • 4-MBC
  • DBMC
  • S-(tricyclo[5.2.1.0’2,6]deca-3-en-8(or 9)-yl) O-(isopropyl or isobutyl or 2-ethylhexyl) O-(isopropyl or isobutyl or 2-ethylhexyl) phosphorodithioate
  • Tris(2-methoxyethoxy)vinylsilane

New SVHC present in the electronics industry

Some of the new SVHCs above affect applications in the electronics industry. Here are some examples:

Table 2: It is interesting to note that ECHA publishes relevant studies and resources to better understand SVHCs.

SCIP database for SVHC notifications

Under Article 33 of REACH Regulation 1907/2006, suppliers must “communicating information on substances contained in articles”.

Therefore, since the beginning of 2021, ECHA has set up the so-called SCIP (Substances of Concern In Products) database to help with the communication of SVHCs. On the SCIP database, we can access millions of product declarations with at least one declarable SVHC.

Importantly, SCIP notifications are mandatory. The obligation to communicate SVHCs impacts both consumer and professional products. Therefore, if an item is not present on the list, it can be assumed that non-declarable SVHCs are present.

How to comply with REACH SVHC

In other words, how could the frequent addition of substances affect existing and developing products? Unfortunately, periodic updates to the SVHC list can cause legal issues for many companies. Fortunately, it is possible to comply with it in a pragmatic way. Here are some tips for setting up a product environmental compliance management system and doing your due diligence. This is the MACC environmental compliance approach:

  1. Monitor applicable requirements. Companies should regularly check the status of Annex XVII of REACH and the SVHC list. Additionally, producers should confirm that their existing or developing products are not affected by the changes. If so, actions 2 to 4 apply.
  2. Assess your product to the new requirements. Since you cannot check every material against every controlled substance, you need to perform risk assessments. Standards can help you adopt the most recognized methods. Literature reviews and, ultimately, analytical testing (chemical analysis) are the two common approaches. You will most likely need to audit your supply chains.
  3. To correct any risk of non-compliance of your products.
  4. Communicate conformity of products to third parties via declarations of conformity, SCIP database, etc.

Finally, do not hesitate to ask experts around you who can advise you and help you find the best strategy thanks to tailor-made solutions.

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