REACH candidate list confronts distribution with new challenges

The EU and ECHA are currently working on new proposals to extend the candidate list with additional SVHC substances (substances of very high concern). This implies that all companies along the supply chain should from now on carefully follow the development of the candidate list on the ECHA website to keep abreast of other candidates identified – because with the publication of the candidate list, the obligations to communicate information become relevant for companies within the EU and the European Economic Area as per Article 33 REACH regulation (see below). The FBDi (/Fachverband der Bauelemente Distribution e.V.// German Association of Component Distributors), a representative body for a large part of the German distribution landscape, is calling for the greatest possible transparency of information from all stakeholders in the supply chain as part of an ongoing communication process. To this end, the Association recently presented a specific proposal for a solution to more than 50 leading companies from the electronics industry. The XML format for communicating information as per Article 33 is specially geared to the needs of the electronics industry. “"Our vision is the definition of a standard, according to which the information about REACH can be collated and processed both cost and resource-efficiently”", explains Wolfram Ziehfuss, director of the FBDi. In making this specific format proposal, on which the manufacturers are to decide by the start of the new year, the Association is setting a further milestone within the scope of its REACH offensive. The current candidate list features a number of substances that are primarily used in the electronics industry: · The substances DBP, DEHP and BBP contained in some synthetic materials · As_2 O_3 and/or As_2 O_5 used as a component in glass and ceramics The objective obligation to communicate information on these substances (if the candidate list substance is contained in a concentration above 0.1 weight by weight in the product) came into effect on 28 October 2008. The distributors of the FBDI are unanimous about the need for action: “We are looking to help our customers in the best way possible in their dealings with REACH. This also involves providing all the available information”, says Ziehfuss. It is now necessary to coordinate a joint information transfer with the formats for the content and an effective system of providing the information. “The willingness to cooperate on the part of the stakeholders is absolutely essential.” Specific solution proposal for a standardised format based on XML This is because, under the REACH regulation, all stakeholders are obliged to ascertain which substances are on the candidate list according to Article 33. As an experienced partner, the FBDI has brought in TechniData, which can draw on its vast store of expertise in environmental issues. One specific proposal for the industry suggests using “CfP-XML” as an IEC-compliant data exchange format based on XML for material declaration, which also supports the automotive and electronics formats IMDS, AIAG, IEEE and IPC PDF 1752. It comprises a standardised XML format for data acquisition, which supports the generation of a technically usable data file. This, in turn, could be processed in other IT systems. In practice, this solution would work as follows: to enable all stakeholders to ascertain any candidate list substances that may be contained in the products as quickly and easily as possible, TechniData would provide a configured DCT with the candidate list substances as *freeware*, along with a short user manual. The Association provides the DCT on its website. Suppliers can then download the DCT from this website, enter the data on the products or send the DCT or the CfP-XML (generated from the DCT) to their customers. This approach offers a number of advantages: · It is possible to select the product/component to be evaluated separately · A table contains the products/components to be declared · The SVHC substances are integrated in the Excel sheet (companies can define other lists). The most important advantage, however, would be that TechniData could update the candidate list substances in collaboration with the Association – i.e. requiring no input on the part of the stakeholders. “Cooperation within the supply chain is without doubt the most essential thing here. The manufacturers are required to supply information in a usable form, which is clear and meaningful, and which leaves no room for interpretation”, explains Wolfram Ziehfuss. “A joint information exchange format, which allows both distributors as well as manufacturers and customers to work on a system-wide basis, is most definitely a giant leap forwards.” The decision phase is now running on the part of the manufacturers, who have until the start of the new year to decide as to whether or not they wish to work with the format presented. REACH Article 33: 1. Every supplier of an item containing a substance of very high concern (SVHC) in a concentration above 0.1 weight by weight, shall provide the recipient of the item with sufficient information, available to the supplier, to allow safe use of the article including, as a minimum, the name of that substance. 2. At the request of a consumer, every supplier of an item containing a substance of very high concern (SVHC) in a concentration above 0.1 weight by weight, shall provide the consumer with sufficient information, available to the supplier, to allow safe use of the article including, as a minimum, the name of that substance. The respective information is to be provided free of charge within 45 days of receiving the request. ECHA: www.echa.europa.eu Image Source: CM