What is the relationship between REACH and RoHS?

UNDERSTANDING REACH

Registration Evaluation Authorization & Restriction of Chemical Substances

By: Mike Levesque, Randy Elliott, Ariann Griffin, & Michael Karg

It is certainly no secret to anyone that the past decade has placed a renewed focus on the environment and how all members of

the world community, to include business organizations, affect it. Concerns about protecting the world in which we live have

been the impetus behind such worldwide movements as recycling and renewable energy. From a manufacturing standpoint, RoHS (Reduction of Hazardous Substances) has impacted businesses as well as REACH, a more recent set of regulations that are becoming more significant to North American based manufacturing operations that are part of a supply chain that directly or indirectly supplies products into the European Union.

As with any new regulatory requirements, the initial exposure to the documentation can create a degree of uncertainty among those who will be asked to comply. From this perspective, REACH is no different from any of its predecessors. In an attempt to offer some understanding of the REACH regulations and some clarification of the requirements it places on manufacturers, C&M Corporation gathered Michael Karg, Director of Product Development, along with Randy Elliott, Regulatory Compliance Engineer, and Ariann Griffin, Regulatory Compliance Technician, to discuss some of the particulars of REACH and respond to some of the questions C&M has been discussing with members of its client base.

What is the purpose of REACH?

REACH (Registration, Evaluation, Authorization, and Restriction of CHemical Substances) is intended to protect human health and the environment by ensuring the intrinsic properties of chemical substances are properly identified. Clearly, if we do not understand what the components of a plastic, for example, are, then we really cannot be certain of any risks the material may represent either during use or later when the material requires disposal. At the heart of it, REACH evolved from a realization that insufficient information was available on many materials to include the hazards they may pose. When REACH went into effect on June 1, 2007, the burden shifted to the manufacturer to prove that the chemicals it produces or uses in its processes are safe for both humans and the environment.

Who is driving the REACH regulations?

The European Union, specifically the European Chemical Agency (ECHA). (The ECHA website address is www.echa.europa. eu) Even though these regulations are focused in Europe, customers and suppliers who are part of the global economy will be impacted with the need to identify and document REACH SVHCs.

What is the relationship between REACH and RoHS?

Both are European Union directives designed to protect both humans and the environment. While RoHS was focused more on heavy metals, REACH covers a significantly longer list of substances. REACH was designed to be a far more encompassing directive for chemicals, including those introduced to the market before 1981.

What are REACH SVHCs?

SVHC is an acronym for Substances of Very High Concern. These include, among other substances, CMRs, which are sub-stances considered to be Carcinogenic, Mutagenic, or Toxic for Reproduction. As we have used the word "substances" several times in this conversation already, and will be using it often as we continue to discuss this topic, it is important to define the word from the REACH perspective. The definition of a 'substance' is a chemical element and its compounds in a natural state or obtained from any manufacturing process. The basic element 'lead' and its compound, lead oxide, would be two examples.