Friday, June 19, 2009: Electrolube, a division of H K Wentworth Ltd, is a manufacturer of electrochemicals for electronics and industrial manufacturing. Atanu Kumar Das of Electronics Bazaar catches up with Amanda Stuart, development chemist at Electrolube, as she speaks about the complex regulations of registration, evaluation, authorisation and restriction of chemical substances (REACH), and how it will impact the exporters of electronic components
EB: What are the benefits of adhering to REACH directives?
If chemicals are not REACH-compliant, there is no market for them in Europe. However, companies that do not export directly to Europe also need to be aware of the regulation if chemicals get exported by their customers, or further down the supply chain. In this case, they should understand the need to communicate information about the chemical down the supply chain.
EB: What is the significance of REACH on products/component exporters?
It is very significant for component/product exporters. Mixtures of chemicals like cleaners, coatings, solder pastes and greases are treated the same as individual chemical substances and the same rules apply. Other products will need to comply with REACH if any chemical is intentionally released in their usage. This is a complicated and vast subject but includes applications like ink in a printer cartridge and lubricants on vehicle components.
EB: What about electronics components and products? Any particular applications or segments within the Indian electronics industry (exporters), which could benefit from this information?
Although a majority of finished electronic goods will be exempt, all products brought into Europe will need to be checked for any chemicals that could be released. The example of lubricants can be applicable to many industries and includes contact lubricants on electronic switches. Thermal pastes, such as HTC, do not cure to form a physical shape after application, so products containing these would be under the scope of the regulation.
EB: Any suggestions for companies that want to adhere to REACH directives?
There are many trade organisations such as ReachReady in the UK, which support the industry and provide training.
EB: Does REACH define the kind of chemicals that need to be ousted from manufacturing processes. If yes, what are they and how cost-effective is it to use substitute chemicals?
Substances that have been put forward as possible substances of very high concern (SVHCs) are listed on a candidate list, found on the ECHA website: http://echa.europa.eu/chem_data/candidate_list_table_en.asp. This has not yet been confirmed as the final list but it is not expected to change much. These substances, which are all either very harmful to human health or the environment, will require authorisation for use in the future. Many European chemical users are aware of this list already and will not buy products that contain them. The availability of alternatives will depend on the specific applications.
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REACH regulation impacts on exporters to Europe
Exporters of electronic components in every country now need to adhere to the objectives laid down by the European Chemical Agency (ECHA), so that they do not face rejections from the European Union (EU). REACH is a new EU wide regulation that affects all areas of the chemical industry and exporters to the EU. Manufacturers and exporters to the EU will be required to gather information on the properties of their chemical substances and register this information in a central database run by the ECHA.
Although REACH is complex, replacing approximately 40 pieces of legislation, its main objectives are clear—to protect against and disseminate awareness about the risks of chemicals to human health and the environment, whilst enhancing the development of the EU chemicals industry.
In the past, research and development in the EU chemicals industry has been somewhat hindered by the slow identification and assessment of risks. Unlike previous directives and regulations, within REACH, the rules for ‘existing’ and ‘new’ chemicals are the same and the responsibility of proving that a substance is safe for the specified uses has been assigned to manufacturers and importers rather than the authorities.
A registration to the ECHA is required for any chemical substance that is brought into the EU in quantities greater than one metric tonne per company, per year. This applies to individual chemical substances, chemical substances used to produce a preparation or blend (ie, a final product) and substances that are intentionally released from articles (an article is an item whose shape, rather than composition, is more significant to its function).
To cope with this massive task of registration and evaluation of the wide array of chemical substances, a phase-in period of 11 years of compliance has been assigned. A six-month period during 2008 was provided, allowing all potential registrants to pre-register the substances they import/manufacture and take advantage of the phase-in period. Without pre-registration, substances cannot be brought into Europe. It is therefore no surprise that chemical suppliers are perpetually contacted by customers seeking assurance of continuous supply.
Exporters to the EU need to be aware of the costs of data collection, safety assessment and registration may make some chemicals unprofitable, leading to limited availability or complete withdrawal from the market. Added to the likelihood that some harmful substances will not be given authorisation for use, there will undoubtedly be a need for alternatives to be identified and formulations of affected preparations altered. The goals of the regulations are being achieved by forcing the manufacturing industry at large, to seek safer alternatives to certain chemicals, and consequently reduce risk to the health of many, as well as the environment.
Although REACH is a European regulation and the responsibility for registration falls on the importers, cooperation between members of the international supply chain is vital for overall success. Importers are required to know the exact chemical identity and quantities of individual substances they bring into the European market from their suppliers.
Electronics Bazaar, South Asia’s No.1 Electronics B2B magazine
