BRUSSELS -- Beginning in August, the EU's REACH Candidate List of Substances of Very High Concern will be updated every six months. 

EU member states' nominations of substances to be added to the list will be published each February and August, says Environ Corp.  

When a new candidate list is published, requirements for suppliers to inform customers whether their products contain any of the substances in concentrations >0.1% w/w begin immediately, says the firm. Component suppliers and equipment manufacturers that supply to businesses are required to inform customers immediately at the point of supply. For products supplied to households, the manufacturer must provide substance declarations within 45 days of request.   

Five months after the first list was published, most product manufacturers are still struggling to gather the necessary data from their supply chains to meet disclosure requirements. In fact, says Environ, many EU component suppliers are still unaware of their legal obligation to inform business customers when they supply parts, components and subassemblies.  

Many US manufacturers believe REACH only applies to manufacturers and importers of chemicals, and trying to gather data for candidate list substances of very high concern from Chinese component and assembly suppliers is proving challenging, according to Environ.   

The prospect of repeatedly having to gather data on new substances of very high concern from suppliers every six months is causing product manufacturers and component suppliers to radically rethink how they communicate substance declarations in the supply chain. A core group of member states has started to draw up a "source list" of chemicals that meets the REACH SVHC criteria. The group aims to complete the list by June.    

Another project underway at ECHA may lead to more stringent substance disclosure requirements for products imported into Europe. The current REACH guidance states the 0.1% w/w concentration threshold applies to the article as produced or imported. However, Austria, Belgium, Denmark, France, Germany and Sweden have refused to accept this interpretation because it requires less substance disclosure for products assembled outside Europe.  

These countries argue the 0.1% threshold should apply to components or homogenous parts of articles. Indeed, Belgium has already announced it will close this loophole for non-EU manufacturers and carry out conformity checks for individual components within assembled products, says Environ. 

 

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