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PCB | September 17, 2008

Is solder supply to the EU at risk beyond 2008?

Concerns that the new EU REACH Regulation will disrupt metal and chemical supply to the EU could begin to be realised by the end of this year if importers don’t begin to take action to deal with this new Regulation. REACH will affect every company within the EU, especially those depending on non-EU suppliers.
However with little or no understanding of how REACH will affect their businesses, and with the first REACH deadline looming at the end of November, there are serious concerns that compliance will not be achieved within the required timescales. This is particularly evident in the electronics solder supply chains, reports ITRI.

Worrying results of a recent survey conducted by IPC (see Figure 1) suggest that the majority of solder suppliers have very limited knowledge of REACH. When asked about awareness and readiness for REACH compliance, most scored a 1 (none) in response to a 10 point scale; a worrying statistic when less than 3 months for pre-registration under REACH remains. Companies may not understand that the implications of not being REACH compliant could well lead to exclusion from the EU market, thus resulting in inevitable interruptions in trade.



“While supply of tin ingots to the EU should continue fairly smoothly due to the actions already taken by metal producers to pre-register, little is known of the plans of tin alloy or solder importers in the EU,” comments Kay Nimmo, Manager of Environmental Affairs at ITRI and Secretariat to the REACH Tin Metal Consortium. “Tin, as well as other metals in alloys imported as bar, wire, and/or paste would all need to be pre-registered under REACH by the EU importer or a representative on behalf of the non-EU producer. It is a concern that only a few solder companies have so far pre-registered for import of tin in alloy form”.

The EU regulation, REACH, came into force on the 1st June 2007, and aims to ensure that information is available on all chemicals and metals manufactured and/or used in the EU, in order to minimise any possible risk to human health or to the environment from these products. Pre-registration, the first requirement of REACH, involves submitting a brief set of information to the Agency, and enables manufacturers and importers to benefit from extended registration deadlines depending on the tonnage band. Companies failing to pre-register their substances before 30th November 2008 will have to suspend manufacture and/or import of those substances straight away. They will need to attempt to register them (with a considerable amount of toxicological, use and exposure related information which may not be immediately available) which will lead to inevitable disruption of the supply chains.
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Since 2005, ITRI has been making preparations for REACH on behalf of the tin industry and has acquired new information on, for example, the behaviour of tin and some of its compounds in the environment. ITRI is acting as the technical programme manager for the REACH Tin Metal Consortium to collect and generate the huge amount of data that tin producers, importers and users will need to cope with REACH.
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