Environmental Protection

Opinion

REACH Urgency

Half of the non-chemical supplier companies doing business in Europe will be shut out of that market on Jan. 1. Are you one of them?

According to a survey published on July 22 by the Association Connection Electronic Industries (IPC) on REACH readiness, “only about half of the companies in the other industry segments [non-chemical suppliers] are taking … basic steps toward compliance."

REACH is a new European Community regulation on chemicals and their safe use. It deals with the Registration, Evaluation, Authorization and Restriction of Chemical substances. If you have not pre-registered all raw materials used in your products (for each intended use) by Jan. 1, 2009, you will not be able to sell your product in Europe. Please note that this sweeping legislation applies to both chemicals and articles such as electronics and electronic components.

SONY was slammed – you can be, too
In October 2001, the Dutch authorities determined that some peripherals supplied for use with Sony’s PlayStation One game console contained one cable with cadmium levels above the limit allowed under Dutch regulations.

Although Sony Computer Entertainment Europe (SCEE) had reservations regarding the interpretation of the applicable regulations, SCEE quickly initiated a plan to rectify the situation. The Dutch authorities gave the company until the end of March 2002 to fully complete the compliance process.

Through a series of aggressive remedial steps taken by SCEE, the company was able to resume shipments within Europe in mid-December 2001 after making modifications and securing appropriate peripherals. However, this disrupted supplies to retail partners and required Sony to rework several product models. This ultimately resulted in reduced revenue for the three months that sales were halted.

Companies that aren’t prepared for the REACH legislation may find themselves in a similar situation – not being able to ship chemicals or products to Europe – and needing to scramble to get paperwork completed to resume shipments. In addition to potential revenue disruptions, they may also be facing fines. The EU has the right to fine companies who don’t meet the deadlines.

Having to divert resources to complete REACH research and paperwork will put other work on hold. Only European companies are eligible to do the pre-registration process. So if your company doesn’t have a European office, you’ll need to find a company that will do the pre-registration for you. Finding a company can be time consuming. Hiring consultants may be very costly if you wait until the last minute or after Jan. 1 because they probably will be in short supply. Higher fees that may be incurred will divert money from other projects.

So if you haven’t started the process of reviewing your chemicals or products to see if they need to be pre-registered, or haven’t made it a top priority, you need to get started NOW.

If you buy components from suppliers to use in your products, you also need written confirmation from them that they have pre-registered the parts you purchase for your intended use. There are consultants in Europe and the United States who can help you with the process. If you need recommendations for companies to help you through this vital step to continue doing uninterrupted business in Europe, you could check trade publications or ask trade organizations or suppliers. Otherwise your 2009 sales forecast could take a sudden downturn.

About the Author

Brenda Romig-Fox is a senior project manager at Quantum Compliance Systems, Inc., an EH&S software company with 20 years of experience solving Fortune 500 companies’ EH&S problems.

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