REACH is a reality for every company planning to manufacture or to import chemicals or articles made with chemicals to the EU. “No data, no market” is a slogan of the chemical regulation initiative, and that announcement shows the level of determination involved. But the electronics industry may have more challenges to face than other industries, when it comes to compliance.
The FBDi , the Professional Association of Component Distribution, a German professional organization, is getting worried about the effects of REACH on makers of electronic components. The chairman of the organization, Georg Steinberger, said, “It is impossible to trace and administer information across hundreds of substances and millions of different products, extending all the way down to the materials chips and capacitors are made of.”
Is the electronics industry different?
Electronics component manufacturers and importers are already covered by RoHS, a European initiative which has been the model for electronics chemical regulation in many more countries in addition to the EU, as well as in the state of California. Conflicts mineral rules also require manufacturers who use tin, gold, tantalum or tungsten (which nearly all electronics components manufacturers do) to determine whether their supply chain leads back to nations which are known as sources of conflict minerals.
So, while REACH 2018 compliance doesn’t involve different requirements for electronics manufacturers, they may already have more other compliance requirements to deal with.
The electronics industry also argues that their products may use more different substances than some other industries use — thus Steinberger’s claim that it is literally impossible to identify every single substance in their articles.
A holistic approach to compliance
It makes sense to think about a cohesive approach to supply chain management. Focusing on individual questions like “Is our tungsten coming from the Congo?” and “Are we using more than a metric tonne per year of cadmium?” can end up creating multiple requests for multiple suppliers. This leads to something common enough to have a name: supplier fatigue. That’s what it’s called when vendors quit answering questions.
Instead, creating a clear picture of substances, suppliers, and requirements all along the supply chain allows all compliance projects to be handled at once. This avoids duplication of efforts, eliminates supplier fatigue, and brings compliance with multiple chemical regulatory regimes back into the realm of the possible.
EUPHOR is a tool designed to make regulatory compliance practical — not just possible. It’s designed to work with all regulatory requirements. Schedule a demo and see how it can streamline the process, even in the electronics industry.