Maybe that's my problem, I was trying to read it in 3pt font... :-) Thanks Bev.
Genny
-----Original Message-----
From: Leadfree [mailto:[log in to unmask]] On Behalf Of Bev Christian
Sent: April 23, 2009 1:58 PM
To: [log in to unmask]
Subject: Re: [LF] REACH questions
Genny,
Have been very busy. I can only answer SOME of oyur questions. See below.
Bev
RIM
-----Original Message-----
From: Leadfree [mailto:[log in to unmask]] On Behalf Of Genny Gibbard
Sent: Monday, April 20, 2009 4:00 PM
To: [log in to unmask]
Subject: [LF] REACH questions
The deadlines are one of the most confusing things about this legislation, especially from the point of view of an article producer outside of the EU. WEEE and RoHS were a little more clear-cut as to when they kicked in. Since we are an article producer, the legislation also affects us a little more indirectly. For example, I don't profess to understand intimately how an IC or a cap or a PWB is manufactured - that isn't what I manufacture, I manufacture circuits that use that IC, cap, and PWB. Fairchild has their area of expertise, I have mine. So how can I always know what substances within our components are at risk? Or am I being naïve?
1. There was a 15 substance 'candidate list' for SVHC released in October. Are they actually official SVHC's or are they still just 'candidates'?
- Well Article 33 obligations started in October of last year, so that sounds pretty "official" to me.
2. I hear there is a list of 7 substances prioritized for authorization in June, and under public consultation right now.
Am I understanding correctly that these 7 substances are part of the 15, or are they in addition to the 15?
- According to the IPC's own EHS update:
REACH SVHC List to Be Updated Every Six Months
Beginning in August 2009, the REACH Substances of Very High Concern (SVHC) List will be updated every six months. Member States' nominations for which substances should be included in the SVHC list will be published in February and August each year. There is increasing speculation about the next batch of nominations for substances to join the SVHC list, which is expected to be published in August. A group of Member States has started to draft a "source list" of chemicals that meet the SVHC criteria. This group aims to complete this list prior to the next REACH competent authorities meeting in June, so that Member States can collaborate on nominating substances for the SVHC list.
REACH requires suppliers to inform their customers if any SVHCs are present in their products in concentrations above 0.1% w/w. Information on the presence of SVHCs above the threshold must also be released to anyone that asks within 45 days. Consumer awareness of their rights under REACH to demand information on the substances in products continues to grow and therefore requests for information on SVHCs is increasing.
3. So if these aren't actually officially approved, yet, can someone actually ask you to report on your REACH substances?
I believe if someone asks, you have 45 days to tell them if your product contains SVHC's.
- I believe they can ask you on the 15 currently on the list.
4. There was a recent thread, where someone said their suppliers weren't REACH compliant. How can you not be REACH compliant if the SVHCs aren't official yet?
How can they even enforce it, yet, until we know which substances will be officially SVHC's? Yes, I know we can be proactive and research all of the 7 or 15 substances and start working to remove them if they exist, but I would take exception to being told I am not compliant, just because I am waiting to see what will be enforced, before I reveal anything.
- See my answers ot quesitons 1 2 and 3.
If I don't have any of the 15 I am clear sailing, for now, I guess, but maybe I am still collecting data.
- You shoud be clear for now - on them. But you still have to worry about RoHS, PFOS, dimethylfumarate, and Coltan (NGO demand).
5. So, as of what day can they start asking for this data and legally expect the report within 45 days?
- Again, I am nolawyer, but I beleive since last October when Article 33 came in to play.
I find this extremely frustrating. Am I missing something crucial? How many of you personally have been able to wade thru all 182 pages of the directive with a clear understanding of how it affects your company?
- Genny the directive is 849 pages in English or do you have something in font size 3?! :)
Just some Monday musings.
If anyone can show that I am wrong on any of my interpreations, I would appreciate it.
Bev
RIM
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