REACH would be an excellent initiative if it were organised conjointly
by UNEP, WHO and WTO, with a truly global reach (pun intended). At least
that would put everyone on exactly the same footing. At the
comparatively parochial European level (even if Europe is now the
world's biggest economy), it would penalise European industry to the
extent that some will certainly be offshored, where they use low volumes
of specialised chemicals, such as are often used by the electronics
industry.
However, I believe it is NOT true that equipment made with the help of
untested chemicals cannot be imported into the EU, unless the said
substance remains unreacted in the finished product. E.g., if a
water-soluble flux contains an unauthorised compound, the product will
be importable, as the substance will be removed during the water-wash.
Similarly, if it is in a no-clean flux and it decomposes in soldering
into authorised substances, it will also be permitted.
As far as importing is concerned, it really applies only to bulk
quantities (>1 tonne/y, if I remember correctly).
Brian
R Sedlak wrote:
> European Union Considers Passing Stricter Chemicals Law; Major Electronics Manufacturers Worldwide Express Concern
>
>
>
> Jul 24, 2006
>
>
>
> The majority of countries with the largest electronics manufacturers outside of Europe are coming together to amend proposed legislation that could have a big impact on the electronics industry outside of the European Union (EU). The EU is considering passing the Registration, Evaluation, Authorization of Chemicals (REACH) legislation. This legislation would only allow chemicals that have been shown to be safe, or where the risks have been examined, to be used in equipment made in or imported into Europe. And the law would mandate full responsibility onto the companies that create and use the chemicals to provide the REACH required paperwork, which could be a big added expense to companies, especially electronics companies. The United States, Japan, India, Korean, and nine other countries have voiced their concerns about REACH, and have expressed their interest in working with the EU to make the proposed legislation more feasible for both sides.
>
>
>
>
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