Doing business today isn’t quite like it was back in the 80’s. Sparkling teeth and x-ray vision shouldn’t be a side effect of a customer using your product. This, of course, is said in jest, but no longer do we sell only a product; but a product and physical, chemical, and electrical compliance data.
Much like the Dodd-Frank Act seeks to regulate the use of Conflict Minerals in products, the European Union addresses the use of harmful chemical substances and their potential impacts on users through REACH. This is why if you do business within the European Union (EU), then you have likely heard of the REACH regulation. In case you haven’t heard of it, REACH stands for Regulation for Registration, Evaluation, Authorization, and Restriction of Chemicals; and was created by the European Chemicals Agency (ECHA).
A Growing List
SVHC Candidate List
The REACH SVHC list is under continual growth and review, and as of mid 2018 it stands at 181 substances. This list has grown steadily since its inception in 2008 through semi-annual updates. ECHA has stated through their roadmap to implementation that by the year 2020 they will have all known SVHC’s included on the candidate list.
In order to be added to the REACH Substances of Very High Concern (SVHC) list, the candidate list for authorization, at least one or more of the criteria as defined in Article 57, shown below, must be met.
- Category 1 or 2 carcinogen, mutagen, toxic for reproduction (CMR)
- Persistent, bio-accumulative and toxic PBT
- Very persistent and very bio-accumulative vPvB
- Other substances for which there is evidence for concern; endocrine disruptors
If the article that you sell contains a substance that is included on the SVHC list in a concentration above 0.1% (w/w) your company will need to inform the customer or recipient of the article with information on how to safely use the article. The full SVHC list can be found here. It should be worth noting, that only the list found on ECHA’s website is considered to be an official list.
The Authorization List is based off of the SVHC Candidate List and currently contains 43 substances. Substances that are on this list can not be manufactured or shipped in the EU after the sunset date has been hit. There are some exceptions to this rule, but the continued use of this substance must outweigh the risk, and must be approved by the Commission. The Authorization list can be found here.
Staying Informed and Legal
Keeping up with the growing list of substances remains the responsibility of the interested party. The manufacturer should be able to provide a CoC stating compliance to REACH for the specified product. ECHA does provide an official registry for companies to check here.
Enforcement of REACH can vary from country to country, and can be quite costly depending on the country and the infringement. Penalties can include fines, imprisonment, and the loss in ability to sell products within the EU.
When ECHA updates the SVHC list, Samtec will survey its suppliers to determine if any of the substances are added to the products they supply to Samtec. Through these responses, Samtec can determine the best way to proceed, and will add these substances to the Samtec REACH CoC. You can find the Samtec’s REACH CoC on our website here.