Syska Voskian Consulting

REACH Compliance for Articles (Discreet Products)

Assessment of Compliance with REACH Responsibilities for Suppliers and Importers of Articles (i.e. Suppliers of discreet products)

The European Regulation REACH (Registration, Evaluation, and Authorization of Chemicals) places specific responsibilities on companies that produce or import “articles” (discrete solid products) in the European market.

The presence of certain substances (“Substances of Very High Concern”) above very low threshold limits must be disclosed to customers of the products (Articles), and if produced in Europe the substance cannot be present unless the European Commission has granted an authorization to the producer.  

Furthermore, the content of substances in articles can be restricted or banned under the restrictions procedure under REACH.

This is one of the more complex areas of REACH in terms of commercial business, which can have significant impact on companies:

Article producers tend to have longer, more complex supply chains which extend globally

The decision if something is a chemical or an article is left to the importer or manufacturer, introducing uncertainty

Different EU Member States continue to have differing criteria and enforcement standards when it comes to defining what comprises the article

Typical situation:

A company supplies a small consumer electronic product to global markets- including Europe;

Assembly of the electronic product is outsourced to an Asian company, using locally produced and imported components;

The finished electronic product includes a power cord, and is supplied with a soft vinyl carrying case which the assembly company has in turn outsourced to another company.

Issue: how to know if the electronic product, as packaged for the consumer, complies with REACH?   Do any of the electronics, such as insulation on any wiring, contain substances that require further actions?  

Does the supplier of a wire harness used inside the product contain a common plasticizer, which is a Substance of Very High Concern?   Similar concern regarding the vinyl case composition.   

To what extent should the company investigate and confirm? And how is the supply within Europe handled with the deviating definition of “articles” in 7 European countries.

Summary of our approach:

•Training on applicable parts of REACH

•Review of current client practice and data

•Review of client products and supply chains to identify priorities/vulnerabilities

•Development of Action Plan for continuing compliance