REACH isn’t working for electronics, says industry group
EU legislation on the registration, evaluation, authorisation and restriction of Chemicals (REACH) has had a “severely negative impact” on the European electronics manufacturing industry, says Adam Fletcher, chairman of the Electronic Components Supply network (escn).
And the divergence of local interpretation and implementations across Europe is adding the industry’s confusion with the legislation.
Fletcher believes REACH is adding new Substances of Very High Concern (SVHC) on an ad-hoc basis, which is causing a huge burden on companies.
He is calling for a single, planned annual release for all new SVHCs to reduce the burden and cost of compliance on its members.
“A huge and unnecessary paperwork chase is going on right across our industry over an issue about which there has been little or no evidence-based research,” said Fletcher.
“Quite frankly it’s a mess” said Fletcher. “Some EU member states are apparently unable to agree whether an article is an electronic component or a finished good.”
“These issues are beginning to undermine our competitive position in a global market,” said Fletcher.
Fletcher believes that the current approach with a “catchall” threshold at >0.1% of SVHC is fundamentally flawed because it has not been subject to rigorous review and does not appear to be based on the actual risk from the substances in articles to health or the environment.
“We suspect it’s just the value that the chemical industry is required by REACH to use for the most hazardous substances in its safety data sheets,” said Fletcher.
“We propose that the threshold should be increased for all existing SVHCs to >1% by weight for electronic systems, which would have no adverse impact on users or the environment because industry has found that it is very rare that suppliers need to provide safe use information to customers with their products,” he said.
At this revised higher threshold level far fewer electronic components and equipment would fall within REACH and this would reduce the burden on the industry whilst satisfying real environmental and health & safety concerns.
“Failure to achieve a well defined, practical implementation and agreed pan-European stance on REACH for the electronic components industry will leave UK (and European) electronic equipment and systems integrators at an increasingly severe technological and financial disadvantage,” said Fletcher.