There are many reasons why the electronics industry should be concerned about the European Union's (EU) chemical law — Registration, Evaluation and Authorization of Chemicals (REACH), and all of these reasons will impact your company's bottom line.

The most important reason is that electronic products are made of chemicals. However, many businesses fail to see that their parts or assemblies are a bill of materials of chemicals that went into processing and manufacturing the parts they use. In addition, many of the chemicals have toxic properties.

You are, no doubt, aware of the impact that the EU's Restriction of Hazardous Substances (RoHS) directive has had on the electronics industry. The restriction of six substances (and as of June 30, seven) required a major redesign of most electronic products covered because of the restriction on the use of lead, cadmium, hexavalent chromium, mercury, PBB and PBDE. Add DecaBDE (brominated fire retardant) effective July 1, 2008 because the European Commission's exemption of DecaBDE was nullified by the European Court of Justice. (See related article: European Court of Justice annuls Deca-BDE RoHS exemption)

Now imagine that the list of products includes virtually everything because the list is not limited to 10 categories of electronic products and the restricted substances now number several hundred. Though the several hundred estimate is likely a worse case scenario for a product category, keep in mind that that the full list of "chemicals of concern" will contain 1,500 to 3,000 entries. Yes, there are a lot of chemicals that are long-term targets of REACH and, if not managed, will have deleterious business impacts.

Impact outside the EU

REACH (2006/121/EC and Regulation (EC) No 1907/2006) impacts both the production and the use of chemicals. Use is a very important part of REACH and is regulated as much as the actual production of the chemical. After chemicals are produced, it is their use that creates potential for exposure. While REACH is a European Directive that will only be enforceable in the EU, it will have impacts far outside the EU.

Like RoHS, REACH will create a list of chemicals that will be incorporated into purchasing agreements that have nothing to do with national chemical restriction laws and everything to do with providing your customers with safer or greener products. If you don't do it, your competition will. Would you buy a product that contains "chemicals of concern" when another vendor offers an equivalent product without those chemicals?

No doubt you have noticed that the electronics supply chain has gone RoHS compliant. This worldwide shift was for an EU requirement. A similar incident occurred in the automotive industry for automotive parts after the EU adopted the End of Life Vehicle Directive. Expect the same under REACH. Just as material declaration forms evolved for RoHS, SAE International working with international partners has created a REACH Materials Declaration scheme, AS9535.

Click here for important REACH acronyms.

What does REACH plan to achieve? Probably first and foremost is the protection of human health and the environment relative to chemicals. Other objectives relate to commercial competition and consistency within the EU. The concern that a new approach to chemical management would put the EU at an economic disadvantage was one of the reasons chemicals in articles is a key part of REACH. You can't make the chemical and the article/product outside the EU and then import it to skirt REACH.

The primary concerns for most electronics firms will be assuring that chemicals they or their supply chain need will be available for manufacturing their products or parts. Next year, the concern will shift to dealing with Substances of Very High Concern (SVHC). Articles with intentional releases such as an ink jet cartridge or an explosive device will be regulated under REACH this year. The current requirement for Safety Data Sheets is based on previous requirements and was the first REACH compliance date, June 1, 2007.