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Front End I AFDEC REACH rethink

Adam Fletcher examines the negative impact of the EU’s REACH legislation on the European electronic components supply chain


he UK (and European) electronic components industry operates in a highly diverse market that is

reliant on international trade to provide the widest possible choice of leading technology solutions to domestic electronic equipment manufacturers and systems integrators.

Whilst undoubtedly well intentioned and laudable in its primary objectives the European Union’s REACH (Registration, Evaluation, Authorisation and restriction of CHemicals) legislation is having a significant impact on the electronics industry. It has spread far beyond the chemicals industries that were its initial target. Its application throughout the European electronics manufacturing industry has had a severely negative impact, confused as it is by a divergence of local interpretation and implementations and the apparently ad-hoc way that REACH is adding new SVHCs (Substances of Very High Concern) to the legislation framework. The current threshold under the REACH legislation for SVHCs is >0.1% by product weight based on the ‘finished good’ regardless of whether it’s a mobile phone or a plane. Some European countries now want to change the basis of the threshold to ‘each individual component within the finished goods’, which would impose an even larger burden on industry yet deliver no apparent benefit to health or the environment.

A huge and unnecessary paperwork chase is going on right across the electronic components industry over an issue about which there has been little or no evidence-based research. Some EU member States are seemingly unable to agree whether an article is an electronic component or a finished good whilst six member States are

opposing the legislation outright. The grounds for this dissent are unclear but could be due to lobbying by environmental groups whose aim is to effectively ban all hazardous substances, irrespective of risk and cost implications and apparently, without regard to changes in a product’s performance, safety and reliability occasioned by the use of alternative materials.

Diverse aims

REACH has diverse aims, a number of which are beginning to undermine Europe’s competitive position in a global market. The candidate list of SVHCs determines substances that require authorisation for use as process chemicals within the EU but puts no restriction on the use of these chemicals when they are present in articles that are imported into the EU. REACH has a procedure for banning very dangerous chemicals that pose a risk to health and the environment but Article 33 sets out not to ban dangerous chemicals but to insure that users of products that contain tolerable levels of defined SVHCs are kept very well informed, causing a huge increase in

manufacturers’ workloads. Logically, where SVHCs are present in very low concentrations that do not pose a risk, there should be no need to provide this highly detailed information. In the UK, electronics trade association ECSN (the Electronic Components Supply Network) is lobbying the relevant UK (and European) legislators to take concerted action to determine a framework to address and mitigate environmental, health and safety concerns about hazardous materials used in electronic components but in a way that does not unilaterally impose unnecessary administrative, legislative and financial burdens on UK (and European) electronic components and electronic equipment industries. The association is calling for a single, planned annual release for all new SVHCs to reduce the burden and cost of compliance on its members. ECSN believes that the current

approach with a “catchall” threshold at >0.1% of SVHC is fundamentally flawed because it has not been subject to rigorous review and does not appear to be based on the actual risk from the defined substances in articles to health or the environment. We suspect it’s just

the value that the chemical industry is required by REACH to use for the most hazardous substances in its safety data sheets. For all existing SVHCs used in electronic systems we propose that the threshold should be increased to >1% by weight, which would have no adverse impact on users or the environment because in the electronics industry it is very rare that suppliers need to provide safe use information to customers with their products. At this revised higher threshold level far fewer electronic components and equipment would fall within REACH and as a result, would remove a significant burden on the industry whilst satisfying real environmental and health & safety concerns.

If the electronic components industry fails to achieve a well defined, practical implementation and agreed pan- European stance on REACH it will leave the UK (and European) electronic equipment and systems integrators at an increasingly severe technological and financial disadvantage. Regional legislation does not work in a global marketplace especially where the largest producers and consumers are based in Asia. The electronics industry has been not been very vocal about the REACH legislation, probably because its impact has not been well understood, however that now needs to change. Whilst individual organisations should become more proactive in lobbying for change only the largest ‘corporates’ are able to afford the time and cost overhead. Our industry needs to apply a much more focused and concerted lobbying effort at both the national and European level and we are confident that ECSN and other relevant European industry trade associations are best placed to effectively address the issues. Technology consultants ERA

Technology Ltd has prepared a Report – “Impact of change definition for REACH article 33 requirements”. CIE readers can request an electronic copy by using the enquiry service provided at

Afdec | ECSN | Adam Fletcher is chairman of AFDEC/ECSN

8 July/August 2011

Components in Electronics

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