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REACH
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REACH Articles
Belgium Found Guilty of REACH Breach: What Does It Mean?
REACH Exposed: Stressing Environmental Compliance
REACH Preparedness Survey
Results
Green EcoSystems Group Announces Green-ES Compliance
Software Solution for REACH and All Other Global Product Toxicity Management Requirements
REACH Exposed:Stressing Environmental Compliance
By Jim Dills, Managing Director, The GoodBye Chain Group
In June 2007, I contributed an article to SMT that focused on the
emergence of environmentally conscious technologies (ECTs), to address
the ever present requirements for greener products and the greening of
manufacturing supply chains. The key factors identified when evaluating
the use of ECT's were toxicity, energy, and waste.
Toxicity requirements have been driven by global product environmental
compliance (PEC) legislation such as WEEE, RoHS, and REACH. ECT
toxicity considerations should include an evaluation of the hazardous
substances used in the manufacturing process as well as the toxic
substances that end up in electronic components, subassemblies, and
finished products. This article provides an update on REACH, the latest
and most demanding piece of toxicity legislation to date. It will help
assess the impact of REACH compliance activities on SMT companies and
their customers and recommend steps to prepare for REACH.
REACH Terminology
Registration, Evaluation, Authorization, and Restriction of Chemicals
(REACH) is the latest piece of European Union (EU) toxicity legislation
aimed at evaluating, monitoring, and restricting the use of hazardous
chemicals or substances used in EU manufacturing facilities and in
products or articles that are put on the market in member states. One
of the new spins to the REACH legislation involves the terminology. To
clarify: chemicals are the same as substances, and articles are the
same as products. Articles are not preparations, solutions, or mixtures
to create solutions, such as cleaning solutions. To keep this
explanation as simple as possible, I will use the terms substances and
articles throughout the remainder of this article.
SMT Companies
Most U.S. companies, including SMT manufacturers and their customers,
will need to contend with toxic substances that are in the articles or
products that they sell. Article manufacturers are affected by REACH if
their article contains substances that will be intentionally released
during normal conditions of use and more than one tonne (1,000 kg) of
the substance is put on the EU market within a one-year period; or
their article contains a substance that is listed as a substance of
very high concern (SVHC) with a concentration value (referred to as
maximum concentration value, or MCV) of greater than 1000 ppm based on
the weight of the substance as a percentage of the weight of the
article.
The one tonne per year "put on the maket" criteria is per importer or
producer. To calculate annual substance tonnage thresholds accurately,
importers and producers must know the aggregate weight of specific
substances in each article at the Chemical Abstracts Service (CAS)
number level. Once that is determined, manufacturers must multiply the
aggregate substance weight in each article by the number of articles
imported into or produced in the EU, determining if the tonnage
criteria for each CAS substance was met. Conversely, an importer must
track the aggregate tonnage from each manufacturer that it purchases
articles from and aggregate the total weight of all of the CAS-specific
substance weights for all articles imported to determine if the amount
of the substance in all of the articles imported from all manufacturers
exceeds the one tonne per annum "put on the market" threshold.
Figure 1. A key requirement will be analyzing articles at the
REACH SVHC level.
The intentionally released criteria are still unclear. To date, the
release of a substance is deemed to be intended when the release of the
substance contributes to the added value of the article and is not
connected directly to the end use function of the article. The example
that has been provided in order for the intentionally released criteria
to apply is the release of perfume from a perfumed eraser (function =
to erase, added value/function for convenience = quality to smell
good).
Understanding SVHCs and their impact on the articles that you produce
is critical. Many companies are still unaware of the SVHC list. In a
nutshell, any substance that is classified as a SVHC will be restricted
if it exceeds the REACH MCV threshold as described above. Restrictions
could include a total ban or limited authorization for specific use
cases. The following substance groups currently are classified as
SVHCs: carcinogens, category 1 or 2; mutagens, category 1 or 2; toxic
to reproduction, category 1 or 2; persistent, bioaccumulative, and
toxic; very persistent and very bioaccumulative; substances that have
endocrine-disrupting properties. These groups include many substances
found in today's SMT articles - lead, nickel, beryllium, antimony,
chromium, PCBs, and a variety of compounds associated with each of
these substances. One of the stark contrasts between REACH and RoHS is
the number of substances that must be tracked and evaluated. RoHS
initially included six substance groups that contained approximately
100 substances. The REACH SVHC list is expected to include
approximately 3,000 substances, increasing the substance tracking and
management activities for SMT companies by 30×.
A key difference between REACH and previous toxicity legislation such
as EU and China RoHS is the method used to calculate the MCV of a
substance in an article. EU RoHS established the concept of
"homogeneous materials;" it was determined that an article would be
judged to be compliant based on a concentration value of less than 1000
ppm based on the weight of the substance as a percentage of the weight
of the homogenous material of which that substance was a part. We
calculate REACH substance-level compliance for an article differently.
It is based on the weight of any of the SVHC substances as a percentage
of the weight of the article. The REACH MCV approach is more helpful to
article manufacturers, as it is easier to be compliant when the
substance weight is a percentage of article weight, not a percentage of
homogeneous material weight.
Analyze Articles at the SVHC Level
Another key difference in REACH versus RoHS is the method in which
articles are defined. Current REACH guidance indicates that the total
weight of an article will be determined by what stage of integration an
article is in when it is imported into the EU. If a substance is
imported as a constituent in a small article, such as a resistor, it
may exceed the MCV based on the weight of resistor. If, however, the
same resistor is imported as part of a subassembly, such as a PCB
assembly (PCBA), then the article may more likely be compliant. This is
a result of the compliance MCV calculation being based on the
aggregated weight of that specific substance in all of the other
articles that make up the subassembly. REACH compliance will be
calculated based on the aggregated substance weight as a percentage of
the PCBA weight versus the substance weight as a percentage of the
resistor weight. If this sounds like it's going to be complicated,
that's because it is. It gets even more interesting when the article is
a finished product, such as a radio, that contains multiple PCBAs. Then
substances must be aggregated across the various components in each of
the boards.
Recommended Actions
SMT companies will be asked by their customers to provide
substance-level information for the articles they sell. Even if an SMT
company does not export products directly to or manufacture in the EU,
one of its customers most likely does and will require substance-level
weight information for each component that it buys. This will apply to
resistors, capacitors, ICs, bare boards, and everything else you can
imagine. As noted earlier, it is easier to be compliant if an article
is a finished product or a subassembly than a single component, so
having substance-level weight data for each component in each
subassembly in each finished product improves both your - and your
customers' - chances of passing the REACH SVHC MCV test for articles.
If you have yet to start collecting full disclosure substance-level
data for your products, start immediately. We know that companies have
resisted data collection activities at this level and we know why,
based on personal experience. It's hard work and the accuracy of data
received always is suspect. To keep your customers happy and reduce the
internal costs associated with PEC activities, we strongly recommend
that SMT companies:
· Create REACH awareness in the supply chain
by sending out letters to all their suppliers, announcing the
requirement for substance-level composition data for all purchased
parts;
· Conduct a risk assessment to determine how
REACH will affect business, disrupt the supply chain, and impact
customer care;
· Prioritize products or product families
affected by REACH and rapidly implement a program to audit their
current compliance status based on analysis of full disclosure
substance-level information;
· As appropriate, conduct a chemical inventory
initially focused on all process and maintenance chemicals currently
being used at EU manufacturing facilities;
· Consider outsourcing REACH data collection,
management, and reporting activities to companies that specialize in
this area.
Jim Dills, Managing Director, The GoodBye Chain Group, may be contacted
at
(719) 488-0500; jdills@goodbyechain.com.
Originally published in SMT May, 2008
Author(s) : Jim Dills
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