Supply Chain Reaction

The EU (European Union) environmental NGOs (non-governmental organizations) through the International Chemical Secretariat has released its "Substitute It Now" (or aptly acronymed "SIN") list of 220 chemical substances considered to be possible Substances of Very High Concern under REACH (Registration, Evaluation, and Authorization of Chemicals).

As a reminder, REACH began on June 1, 2007, and aims to streamline and improve the former legislative framework for chemicals in the EU. Under REACH, manufacturers and importers must register substances they produce or import in quantities of one ton or more per year per company by end of 2008. These companies may not use any substance that REACH determines to be a Substance of Very High Concern in products unless granted authorization.

Electronics supply chain watchers at Design Chain Associates reported that the SIN list was introduced at a conference held Wednesday in Brussels. The European Chemicals Agency had published a proposed list of 16 substances earlier this month.  Design Chain Associates had its director of EU law and policy, Kris Pollet, at the Brussels meeting and reported that the European Chemicals Agency expects the first candidate list to be approved on October 22.

Substances on the lists are considered to carcinogenic (C); mutagenic (M); toxic for reproduction (R); persistent, bio-accumulative and toxic (PBT); or very persistent and very bio-accumulative (vPvB). 

As REACH determines, if any of the 16 substances are contained in a product after the list's approval date in an amount above 0.1% weight-by-weight that inclusion must be disclosed and "safe use" information must be passed to the customer.

Design Chain Associates further reported that authorizes at the meeting loosely said the industry can expect the candidate list to be updated annually. Many in the electronics supply chain are concerned by this tactic. A short list may be easier to digest for now, but longer term the additions will add up, as will the electronics industry's time and cost per implementation, and many have suggested a cold-turkey, get-it-over-with approach would be best for chemicals removal from the electronics design process.

"Our belief is that the NGOs are frustrated at the fact that only 16 substances were on the initial proposed candidate list. Frankly, the EU has over 1,000 substances already classified as PBTs, CMRs category 1 or 2, or 'of equivalent concern' to pick from. They, perhaps like many in industry, expected (and in the NGOs' case, desired) the entire list to be immediately proposed," Design Chain Associates said.

"ChemSec marshaled scientists from academia and elsewhere across the globe to help compile this list over the last several months. We therefore suggest that you do not take this lightly, even though the European chemical industry is not happy about it. It is a serious list compiled through the efforts of serious scientists," Design Chain Associates advised.

For more on REACH, see Design Chain Associates' Web site on the regulation. And voice your comments on the SIN list below. How seriously are you taking REACH? And how would possible regulation on the listed 220 substances, not to mention the 16 substances to most likely begin regulation next month, impact your design?