reach and its impact on electrical and electronic component exports to europe (within reach &...
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REACH and its impact on electrical and electronic component exports to Europe
(within REACH & Substance in Article)
Shrirang Bhoot
REACH Support
REACH and ErP Sensitization workshop 9th Sept’10 (Bangalore) & 10th Sept’10 (Chennai)
Contents REACH in brief
Electrical & electronic components implicated under substance in
articles
Substances of concern used in electrical & electronic components
Leather articles implicated & SVHC used
Compliance procedures for the Indian exporters
Information for Communication
Summary of obligations for non-EU exporters
REACH and ErP Sensitization workshop 9th Sept’10 (Bangalore) & 10th Sept’10 (Chennai)
REACH - Basics
• Pre-registration & Registration by non-EU manufacturer
through an OR• Evaluation (of some substance dossiers) by the
competent authorities in Member States• Authorization (of some hazard substances ) by ECHA for
specific use/ application• Restriction on placing of very hazardous CHemical
substances in the EU market
REACH and ErP Sensitization workshop 9th Sept’10 (Bangalore) & 10th Sept’10 (Chennai)
What is an Article
"Article means an object which during production is
given a special shape, surface or design which
determines its function to a greater degree than its
chemical composition;"
E.g. furniture, clothes, vehicles, books, toys, kitchen equipment and electronic equipment, leather jackets, leather gloves, etc.
REACH and ErP Sensitization workshop 9th Sept’10 (Bangalore) & 10th Sept’10 (Chennai)
Electrical & electronic components - Subs in articles
REACH and ErP Sensitization workshop 9th Sept’10 (Bangalore) & 10th Sept’10 (Chennai)
Leather Products- Subs in articles
REACH and ErP Sensitization workshop 9th Sept’10 (Bangalore) & 10th Sept’10 (Chennai)
REACH Requirements for Substances in Article
Essentially two requirements
1. Pre-registration & Registration of substances released from the article during normal or foreseeable conditions of use provided:
Release is intentional (e.g. – perfume from the eraser, perfume from scented candles)
Intentional release – Deliberate and contributes to an added value of the article
Substance (which is released) is present in greater than one ton in the export consignment (per annum)
The substance has not been registered for that use
2. Notification of SVHC substances if:
SVHC is greater than 0.1% wt by wt (1000 ppm)
REACH and ErP Sensitization workshop 9th Sept’10 (Bangalore) & 10th Sept’10 (Chennai)
What are SVHC
Substances of Very High Concern are:• PBT substances• vPvB substances• CMR category 1, 2 substances Substances of equivalent concern (having endocrine disrupting properties)
REACH and ErP Sensitization workshop 9th Sept’10 (Bangalore) & 10th Sept’10 (Chennai)
Possible SVHC used in Electrical & electronic components
Sr. No. Chemical Name EC number
1 4,4’- Diaminodiphenylmethane (or methylene dianiline) 202-974-4
2 Dibutyl phthalate (DBP) 201-557-4
3 Cobalt dichloride 231-589-4
4 Sodium dichromate, dihydrate 234-190-3
5 Bis (2- Ethyl (hexyl)phthalate) (DEHP) 204-211-0
6 Hexabromocyclododecane (HBCDD) and all major diastereoisomers identified: (Alpha-, Beta-, Gamma-) hexabromocyclododecane
247-148-4 &221-695-9
7 Benzyl butyl phthalate (BBP) 201-622-7
8 Triethyl arsenate 427-700-2
9 Lead hydrogen arsenate 232-064-2
10 Coal tar pitch, high temperature 266-028-2
REACH and ErP Sensitization workshop 9th Sept’10 (Bangalore) & 10th Sept’10 (Chennai)
Possible SVHC used in Leather Articles
Sr. No. Chemical Name EC number
1 4,4’- Diaminodiphenylmethane (or methylene dianiline) 202-974-4
2 Dibutyl phthalate (DBP) 201-557-4
3 Cobalt dichloride 231-589-4
4 Sodium dichromate, dihydrate 234-190-3
5 Bis (2- Ethyl (hexyl)phthalate) (DEHP) 204-211-0
6 Anthracene 204-371-1
7 Benzyl butyl phthalate (BBP) 201-622-7
8 Alkanes C10-13, chloro (Short chain chlorinated paraffins) PBT 287-476-5
REACH and ErP Sensitization workshop 9th Sept’10 (Bangalore) & 10th Sept’10 (Chennai)
Obligations of Indian Electrical & electronic components Exporters
Exporters need to check with their suppliers if listed SVHC are present in the chemicals they purchase and use in their process.
If yes, check if the content of SVHC in the component is higher than 0.1% wt/wt (1 g/kg)
If > 0.1% wt/wt, Notification requirements within REACH will apply
In addition, there is a duty to communicate for any supplier of an article containing a SVHC substance sufficient information, to allow safe use of the article
REACH and ErP Sensitization workshop 9th Sept’10 (Bangalore) & 10th Sept’10 (Chennai)
Obligations of Indian Leather Exporters
Tanners need to check with their suppliers if listed SVHC are present in the chemicals they purchase and use in their process.
If yes, check if the content of SVHC in the leather is higher than 0.1% wt/wt (1 g/kg)
If > 0.1% wt/wt, Notification requirements within REACH will apply
In addition, there is a duty to communicate for any supplier of an article containing a SVHC substance sufficient information, to allow safe use of the article
REACH and ErP Sensitization workshop 9th Sept’10 (Bangalore) & 10th Sept’10 (Chennai)
Notification Requirements to the ECHA
The information to be notified includes the following:
• The identity and contact details of the producer • The registration number (s) for the substance, if available • The identity of the substance (s) like name of the substance,
CAS, EINECS No, etc • The classification of the substance, which will be available from
the Agency • A brief description of the use (s) of the substance in the article
and of the uses of the article (s) • The tonnage range of the substance, i.e. 1-10 tonnes, 10-100
tonnes etc.
REACH and ErP Sensitization workshop 9th Sept’10 (Bangalore) & 10th Sept’10 (Chennai)
Notification Deadlines
For substances included in the SVHC list before 1 December 2010, the notifications have to be submitted not later than 1 June 2011
For substances included in the SVHC list on or after 1 December 2010, the notifications have to be submitted no later than 6 months after the inclusion
REACH and ErP Sensitization workshop 9th Sept’10 (Bangalore) & 10th Sept’10 (Chennai)
Information for Communication
S. No Item Example
1. Substance name Diarsenic trioxide
2. CAS Number 1327-53-3
3. Reg. No (if provided) -
4. Classification Carc. Cat. 1; R45; T+; R28; C; R34 ; N;R50/53May cause cancer
5. Conc. in article 1 % wt/wt
Safe handling S53, S45, S60, S61
6. Safe disposal This article should be disposed of as hazardous waste. Please do not put it in your normal household waste
REACH and ErP Sensitization workshop 9th Sept’10 (Bangalore) & 10th Sept’10 (Chennai)
Conclusion – Obligations of Indian Exporters of Articles within REACH
Assess whether there will be an intentional release
No (Pre-registration/Registration requirements do not apply
Yes (Estimate quantity of the substance in article, if exceeding 1 ton per annum in total exports Registration requirements apply
If no intentional release, assess for the presence of SVHC
Supply chain communication for SVHC in chemicals used in electrical & electronic equipments
SVHC present in over 1000 ppm (1g/Kg), Notify to ECHA
SVHC present below one ton, duty to communicate safe use of article to buyers and downstream users
REACH and ErP Sensitization workshop 9th Sept’10 (Bangalore) & 10th Sept’10 (Chennai)
REACH and ErP Sensitization workshop 9th Sept’10 (Bangalore) & 10th Sept’10 (Chennai)