REACH and its impact on electrical and electronic component exports to Europe (within REACH &...

REACH and its impact on electrical and electronic component exports to Europe

(within REACH & Substance in Article)

Shrirang Bhoot

REACH Support

REACH and ErP Sensitization workshop 9th Sept’10 (Bangalore) & 10th Sept’10 (Chennai)

Contents REACH in brief

Electrical & electronic components implicated under substance in

articles

Substances of concern used in electrical & electronic components

Leather articles implicated & SVHC used

Compliance procedures for the Indian exporters

Information for Communication

Summary of obligations for non-EU exporters


REACH - Basics

• Pre-registration & Registration by non-EU manufacturer

through an OR• Evaluation (of some substance dossiers) by the

competent authorities in Member States• Authorization (of some hazard substances ) by ECHA for

specific use/ application• Restriction on placing of very hazardous CHemical

substances in the EU market


What is an Article

"Article means an object which during production is

given a special shape, surface or design which

determines its function to a greater degree than its

chemical composition;"

E.g. furniture, clothes, vehicles, books, toys, kitchen equipment and electronic equipment, leather jackets, leather gloves, etc.


Electrical & electronic components - Subs in articles


Leather Products- Subs in articles


REACH Requirements for Substances in Article

Essentially two requirements

1. Pre-registration & Registration of substances released from the article during normal or foreseeable conditions of use provided:

Release is intentional (e.g. – perfume from the eraser, perfume from scented candles)

Intentional release – Deliberate and contributes to an added value of the article

Substance (which is released) is present in greater than one ton in the export consignment (per annum)

The substance has not been registered for that use

2. Notification of SVHC substances if:

SVHC is greater than 0.1% wt by wt (1000 ppm)


What are SVHC

Substances of Very High Concern are:• PBT substances• vPvB substances• CMR category 1, 2 substances Substances of equivalent concern (having endocrine disrupting properties)


Possible SVHC used in Electrical & electronic components

Sr. No. Chemical Name EC number

1 4,4’- Diaminodiphenylmethane (or methylene dianiline) 202-974-4

2 Dibutyl phthalate (DBP) 201-557-4

3 Cobalt dichloride 231-589-4

4 Sodium dichromate, dihydrate 234-190-3

5 Bis (2- Ethyl (hexyl)phthalate) (DEHP) 204-211-0

6 Hexabromocyclododecane (HBCDD) and all major diastereoisomers identified: (Alpha-, Beta-, Gamma-) hexabromocyclododecane

247-148-4 &221-695-9

7 Benzyl butyl phthalate (BBP) 201-622-7

8 Triethyl arsenate 427-700-2

9 Lead hydrogen arsenate 232-064-2

10 Coal tar pitch, high temperature 266-028-2


Possible SVHC used in Leather Articles

Sr. No. Chemical Name EC number

1 4,4’- Diaminodiphenylmethane (or methylene dianiline) 202-974-4

2 Dibutyl phthalate (DBP) 201-557-4

3 Cobalt dichloride 231-589-4

4 Sodium dichromate, dihydrate 234-190-3

5 Bis (2- Ethyl (hexyl)phthalate) (DEHP) 204-211-0

6 Anthracene 204-371-1

7 Benzyl butyl phthalate (BBP) 201-622-7

8 Alkanes C10-13, chloro (Short chain chlorinated paraffins) PBT 287-476-5


Obligations of Indian Electrical & electronic components Exporters

Exporters need to check with their suppliers if listed SVHC are present in the chemicals they purchase and use in their process.

If yes, check if the content of SVHC in the component is higher than 0.1% wt/wt (1 g/kg)

If > 0.1% wt/wt, Notification requirements within REACH will apply

In addition, there is a duty to communicate for any supplier of an article containing a SVHC substance sufficient information, to allow safe use of the article


Obligations of Indian Leather Exporters

Tanners need to check with their suppliers if listed SVHC are present in the chemicals they purchase and use in their process.

If yes, check if the content of SVHC in the leather is higher than 0.1% wt/wt (1 g/kg)

If > 0.1% wt/wt, Notification requirements within REACH will apply

In addition, there is a duty to communicate for any supplier of an article containing a SVHC substance sufficient information, to allow safe use of the article


Notification Requirements to the ECHA

The information to be notified includes the following:

• The identity and contact details of the producer • The registration number (s) for the substance, if available • The identity of the substance (s) like name of the substance,

CAS, EINECS No, etc • The classification of the substance, which will be available from

the Agency • A brief description of the use (s) of the substance in the article

and of the uses of the article (s) • The tonnage range of the substance, i.e. 1-10 tonnes, 10-100

tonnes etc.


Notification Deadlines

For substances included in the SVHC list before 1 December 2010, the notifications have to be submitted not later than 1 June 2011

For substances included in the SVHC list on or after 1 December 2010, the notifications have to be submitted no later than 6 months after the inclusion


Information for Communication

S. No Item Example

1. Substance name Diarsenic trioxide

2. CAS Number 1327-53-3

3. Reg. No (if provided) -

4. Classification Carc. Cat. 1; R45; T+; R28; C; R34 ; N;R50/53May cause cancer

5. Conc. in article 1 % wt/wt

Safe handling S53, S45, S60, S61

6. Safe disposal This article should be disposed of as hazardous waste. Please do not put it in your normal household waste


Conclusion – Obligations of Indian Exporters of Articles within REACH

Assess whether there will be an intentional release

No (Pre-registration/Registration requirements do not apply

Yes (Estimate quantity of the substance in article, if exceeding 1 ton per annum in total exports Registration requirements apply

If no intentional release, assess for the presence of SVHC

Supply chain communication for SVHC in chemicals used in electrical & electronic equipments

SVHC present in over 1000 ppm (1g/Kg), Notify to ECHA

SVHC present below one ton, duty to communicate safe use of article to buyers and downstream users


REACH and its impact on electrical and electronic component exports to Europe (within REACH &...

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