Manufacturers collaborate on scheme for REACH compliance

An industry collaboration is under way to manage compliance with the EU REACH Regulation, RoHS Directive and other substance restrictions and declaration requirements.

The collaborating companies - who include Philips, Siemens, OSRAM, Agfa, Tyco Electronics, and Toshiba - are using Environ’s BOMcheck web database. This gathers substance declarations from suppliers and then rolls up the data to calculate REACH compliance for finished products.

Philips said that the companies would share their experiences and approaches to using BOMcheck at a breakfast workshop on 9 November in Vienna at the Going Green – Care Innovation 2010 conference.

The REACH Regulation requires OEMs such as Philips to inform consumers if their finished products contain more than 0.1% w/w of any of the Substances of Very High Concern (SVHCs) on the REACH Candidate List. There are already 38 SVHCs on the list and the European Chemicals Agency intends to add another 106 SVHCs by December 2012 by updating the list every 6 months. The next update is due in December 2010 when another 11 substances will be added to the list.

In the past, Philips and other OEMs required their suppliers to sign one statement each year to declare compliance to a Restricted Substances List. However, Philips said that, under REACH, it needs to know the concentration of SVHCs in each component part so it can add up the data for the finished product. This is not possible with a paper-based approach.

“Philips selected the BOMcheck system because it is the easiest and most robust system for suppliers and OEMs to use” said Jan-Willem Scheijgrond, senior director for Environment, Health & Safety at Philips Corporate. “All OEMs aligned their requirements to share one list of regulated substances and one database. This collaborative approach simplifies the sharing of substances information across supply chains without compromising supplier confidential information.  We believe that BOMcheck can become the industry standard and can stop the proliferation of company-specific declaration tools”.   

Philips and other leading OEMs encourage suppliers to make a Full Materials Declaration (FMD) because then they do not need to update their declaration every six months when more substances are added to the REACH Candidate List and other regulatory requirements. To make an FMD, the supplier lists all of the materials in the part and then all of the intentionally added substances in each material. For suppliers with simple parts (e.g. cables, housings etc) it takes less time to make an FMD than to work through the list of restricted and declarable substances in the RCD tool.

BOMcheck uses the suppliers FMD to calculate an RCD for their parts, and then automatically re-calculates the RCD when the list of regulated and declarable substances changes. Suppliers can choose to make the FMD confidential to themselves (or selected customers) and allow other customers only to see the RCD which BOMcheck calculates from the FMD. Suppliers can map their part numbers to their customers’ part numbers and can also e-mail substance declarations data (in PDF,CSV or XML format) directly from BOMcheck to any of their customers who have not joined BOMcheck yet.

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