The European Chemicals Agency (ECHA) has updated its guidelines regarding communication and notification obligations of companies when substances of very high concern are contained in products and materials (articles). Although the ECHA has updated their guidelines to reflect the judgement of the Court of Justice of 10 September 2015 in case C-106/14, complexities of the regulation continue to make achieving compliance a complicated task.
“The new ECHA guidelines help – but REACH remains a very complex compliance process,” said Jess Kraus, CEO of Source Intelligence.
“Companies at all stages of the supply chain need to be educated on REACH. Education is paramount to accurate data exchange and companies should understand the importance of educating all levels of their supply chain. At Source, we’ve found that educating suppliers on the origin of the data request not only speeds up response time but increases the accuracy of the data.” Kraus said.
The new ECHA guidelines help – but REACH remains a very complex compliance process.Jess Kraus
The more comprehensive guidelines were published in late June primarily to further help small- and medium-sized enterprises (SMEs) meet the next deadline to register their processes, products or imports containing substances that pose potential harm to humans and/or the environment. The next registration deadline for substances of very high concern (SVHCs) produced or imported in the European Union in quantities of 1 ton or more a year is May 31, 2018.
This deadline is a concern for many SMEs because the list of chemicals has expanded and the threshold for reportable quantities is lower. Thus, more small- and medium-sized enterprises throughout the EU are expected to be in scope of reporting requirements.
Under REACH, companies have the responsibility of collecting information on the properties and uses of substances that they manufacture or import. The REACH reporting process is multi-step:
- Companies must make assessments of the hazards and potential risks presented by a listed substance
- Register SVHCs found their products
- Ultimately, notify customers (“downstream users”) and employees that these substances are present
The updated guidance includes examples and clarification about the scope of communication and notification obligations, particularly regarding SVHCs in “complex” products like automobiles, washing machines, mobile phone, aircraft or even a bank card with a chip.
For many SMEs without the internal resources available to large international corporations, REACH compliance typically means looking to third-party vendors.
At Source Intelligence, we aim to ease the burden of data exchange up and down the supply chain. Our platform allows enterprises and suppliers to easily upload REACH documents and get real time chemical statuses. We bring value to companies with our extensive SVHC data, and our ability to flag anomalies in the chain of custody of supplies and semi-finished goods.
For more information about REACH, as well as other government regulations concerned the reporting of hazardous materials, click here.