Definition & Purpose
REACH - Registration, Evaluation, Authorization and Restriction of Chemicals
REACH is an expansive set of European Union regulations that affects all industries doing business in the EU. It basically puts the responsibility for chemical safety on the manufacturers of those chemicals, and brings the EU under one unified set of regulations. An important objective of these regulations is to encourage, and in certain situations, ensure chemicals of high concern are replaced with less dangerous chemicals or eliminated.
Ongoing draft recommendations for substances of very high concern (SVHC)
The European Chemicals Agency (ECHA) on 1/14/09 developed the first draft recommendation of substances of very high concern (SVHC) for inclusion in Annex XIV. There are now over 50 SVHCs and the list keeps growing.
Company Position
Triad Electronic Technologies (Triad), being a contract manufacturer of electronic assemblies, has no active role in these new regulations. Although electronic components and supplies can be characterized as articles and substances, Triad is not considered a source manufacturer of components or supplies, importer, or registrant under Article 3 of REACH. Any supplies procured by Triad in order to assemble electronics according to the customer design, are under the responsibility of the supplier to register. Triad has limited responsibility to communicate SVHC information down the supply chain when provided by the manufacturer, per article 33 of the directive.
Triad expects manufacturers to have robust environmental programs that adhere to the requirements of REACH, identify SVHC to Triad, and thus provide a Safety Data Sheet or other document prescribing the safe handling of their products which contains SVHCs in excess of 0.1% in any of the products homogenous materials. This is not always the case as manufacturers are free to comply or not comply with environmental laws from other countries. Customers wishing to ensure purchased products are free of SVHCs should choose component manufacturers that openly and publicly support REACH.
Triad has made suppliers aware of our above expectations and has asked for documentation indicating their support and commitment to comply with REACH. When possible, said documentation is archived by Triad.
When Triad is made aware of the presences of SVHC, we will communicate this to our customers, and provide them with a safety datasheet as required by article 33 of REACH. Safety Datasheets are meant to instruct the end-user (customer) on safe handling of the product with the SVHC. In most cases the amount will be small and encapsulated in the component. Exposure to the SVHC would require grinding the component up. This is not a normal way of handling the product, and a safety datasheet should reflect this distinction.
Triad manufactures a very wide selection of customer designed products. As with RoHS, not all the products we manufacture will be REACH compliant at one time. For this reason, Triad cannot sign a global agreement on REACH Compliance. Customers must take an active role in understanding environmental compliance of product and selecting products accordingly.