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As the REACH regulatory activities move on around the world,
like RoHS, the electronics industry will have to assess the
law’s impact and modify their products accordingly. So far,
it is difficult to estimate just how much changes have to be
made by factories to comply with REACH.
As talked to manufacturers in Hong Kong, most of them have
not engaged in preparing for REACH yet. “OEMs start to
become aware of REACH. However, RoHS has drawn so much
people’s attention & resources. People do not have time
to study it,” says one of the analysts from local authorities.
Some companies finished their RoHS project applying a
one-time project mode. Without developing environmental
compliance strategies, they suffer from this second wave
of compliance. The reasons are simply because the same
sort of efforts required for RoHS compliance will apply to
REACH as well as other environmental compliance legislation
such as the EU packing directives and the many U.S. state
substances bans such as the mercury restriction in Massachusetts.
Not like RoHS, the REACH directive will not have as much an
impact on the electronics industries as it will have on OEMs
who use a larger portion of toxic chemicals in their products
and manufacturing processes. REACH’s impact will not be as
great as it will be on other industries such as cosmetics
and textiles.
One of the major concerns – around both RoHS and REACH –
is that a plethora of laws in various nations, states and
provinces will make compliance difficult if not impossible.
OEMs certainly can’t build different products to comply with
the requirements of individual geographical territories, so the
preferred solution is to build a product that complies with most of
their target markets. On top, it would be manufacturers to
determine what to build within their management system or
infrastructure to tackle compliance in the long run.
REACH stands for Registration, Evaluation and Authorization of
Chemicals. REACH is designed to be an integrated approach to
the control of the production, import and use of chemicals in
Europe. It aims to create a system which is based on information
about chemicals, and which ensures that useful safety information
gets to those using chemicals. The REACH system is quite complex,
though so are the network of 40 or so regulations that it is replacing.
Crucially, in REACH the main responsibility for chemical safety is
clearly placed on the chemical producer or importer (into the EU),
not on public authorities or downstream users.
it describes the phased process to overcome the lack of data on
existing chemicals (sometimes referred to as the ‘burden of the past’)
– including a series of deadlines, based on tonnage, for
registering information on existing chemicals.
This should mean that information on all existing substances
manufactured in, or imported into, the EU in tonnages of 1
tonne or more per year should be available within 11 years
of REACH entering into force. it lays out the regulatory system
for the management of chemicals in the EU. For example,
information requirements for all ‘new’ substances, the system
for the control of substances of very high concern, and the
information that should pass both up and down the supply chain.
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