What REACH expects from a US company

US companies that are requested to provide information on Substances of Very High Concern (SVHC) under the REACH (Registration Evaluation Authorization and restriction of Chemicals) regulations might be wondering what has hit them.

At a minimum, they will be asked for the name of the SVHC in the “articles” (the REACH wording for products) that you supply. They will also be asked to provide, where appropriate, Safe Use Data.

So what kind of content should be included in the Safe Use Data? The European Chemicals Agency (ECHA) has issued comprehensive guidance on this important subject, which is a legal obligation for manufacturers and downstream users in Europe. It differentiates between advice to consumers and professional users.

For example, consumers might be advised to keep a substance out of the reach of small children, avoid dermal exposure by not wearing certain clothing, or handle waste as hazardous.

Professionals could be warned against dust inhalation from grinding, to ensure that appropriate personal protection is used, and to avoid leakage to the environment if using a product outdoors in the rain.

A typical safety checklist might be:
Exposure controls/personal protection
Handling and storage
Disposal consideration
Fire-fighting measures
Transport information

Information can be included in safe use, or instructions for use data, and labels may be required in some cases.

Simply linking to Web sites, without clear instruction of where to find the product level information and Safe Use Data, will not be deemed sufficient in Europe. US companies could find the importer very persistent, as the obligation to provide this information downstream then falls upon them.

About the author
As director of legislation and environmental affairs, Gary Nevison is Newark’s and Farnell’s spokesperson and customer interface on legislation that affects the electronics industry, such as the ROHS (all variations around the world), REACH, EuP, and WEEE directives. For more on Gary, click here.