Seven steps on navigating the new set of regulations for those importing assemblies to the EU.

The requirements of the European Union’s REACH (Registration, Evaluation, Authorization and Restriction of Chemicals) Directive are massive and involve manufacturers and importers of chemicals, compounds and articles. Here are seven basic points about REACH that every manufacturer of electronics assemblies selling product in Europe must understand.

1. No data, no market. If your company builds electronic assemblies for import into the EU, you are directly impacted by the REACH requirements. Failure to comply with these new regulations risks having your products denied access to the European market.

2. Reporting requirements. Electronic components are “articles” under the definition of REACH, as are electronics assemblies, and are subject to specific reporting requirements with regard to Substances of Very High Concern (SVHCs). The REACH Directive requires that SVHCs be controlled, reported, and eventually phased out in favor of safer materials when it is technically and economically feasible.

The manufacturer of electronics assemblies must determine if the electronic components used in their products contain any of the SVHC restricted chemicals/substances. If present, REACH requires that importers to Europe of articles, or manufacturers of articles in Europe, provide information on SVHCs greater than 0.1% w/w in the article to the immediate downstream recipient and to any other consumer that requests it. This requires the manufacturer to aggregate the total weight of each SVHC contained in its finished product and represent it as a percentage of the total weight of its product. This information must be provided free of charge and made available within 45 days.

Starting in 2011, manufacturers and importers also will be required to report this information directly to European Chemical Agency (ECHA) if it is greater than 0.1% w/w and the manufacturer imports greater than one metric ton of the SVHC into Europe each year. However, manufacturers need not report this information if they can demonstrate that the substance is already registered for the same use, or prove that the SVHCs in their product cannot be released during its lifecycle or during the disposal process.

3. Why the concern about SVHCs? SVHCs have major health consequences. These are chemicals or substances that have been demonstrated to be carcinogens, mutagens and reproductive toxins; or they have been identified as being persistent, biocumulative and toxic; or fall into a category considered “Substances of Equivalent Concern,” which includes endocrine disruptors.

ECHA identifies SVHCs on what the industry has come to call the “SVHC Candidate List” (Candidate Substances for Authorization). The initial “Candidate List” includes fifteen chemicals/substances and can be accessed at http://echa.europa.eu/chem_data/candidate_list_table_en.asp.

Over time, many more chemicals and substances will be added to the Candidate List, with some experts estimating as many as 1,500 SVHCs eventually will be identified.

4. Sunset date. At some point in the future, ECHA will designate a “Sunset Date” for each SVHC. After that date, manufacturers will be required to stop using the component containing the SVHC or to obtain specific ECHA authorization to continue using the component. Firms seeking authorization to continue using an SVHC after the Sunset Date must demonstrate that the socioeconomic benefits from its use outweigh the SVHC risk to society.

To maintain a global market for their products, component manufacturers will eventually have to replace SVHCs with substitute chemical/substances. If the electronics industry’s experience with the European RoHS directive is any indication, this Sunset provision will result in the discontinuance of many components and the performance requalification of others.

5) No part number change. There is no indication component manufacturers will change part numbers as a result of the migration to substitute chemical/substances, and there is no official “REACH Compliant” designation for the component as there was with RoHS-compliant components. As such, there will be no component marking or labeling, making identification between a part number containing the SVHC and the same part with a substitute chemical/substance problematic. This situation becomes enormously more complicated when you consider that a component may have multiple SVHCs that are phased out of the component manufacturer’s supply chain at different points in time.

6. Obtain SVHC information from component manufacturer. Only the component manufacturer is in position to provide detailed SVHC data on the electronics components that they manufacture. They control the manufacturing process, and only they are in position to know when their internal processes change or when they change raw material vendors. The industry will be best-served if component manufacturers work together to uniformly list SVHC data openly on their websites using standard material data reporting formats.

7. Establish a REACH task force. As with the RoHS transition, many firms are underestimating the time, expense and energy necessary to meet all REACH requirements. REACH is much more complicated than RoHS and will grow in complexity over time. Each company in the electronics industry, if not already doing so, should establish a cross-functional task force composed of engineering, quality, purchasing, operational, finance, marketing, IT, legal and other personnel to begin tackling this latest EU environmental initiative.

While REACH is expected to have a significant long-term impact on the electronics supply chain, distributors can help minimize the impact. Distribution plays a central role in the supply chain and the unique ability to facilitate communication between OEMs and component makers. Further, diverse technical resources offered by distributors can help guide OEM design engineers by offering component options that don’t include non-registered chemicals or SVHCs. By establishing open communication channels early on with authorized distributor partners, manufacturers and importers of chemicals, compounds and articles can help minimize the possibility of future supply chain disruptions.

Steve Schultz is director, strategic planning and communications, Avnet Logistics (avnet.com); steven.schultz@avnet.com.