|
Konsekvenser af REACH for elektronikvirksomheder – krav til downstream brug af præparater og fremstilling af artikler Summary and conclusionsCompanies within the electronics industry are manufacturers, importers and suppliers of electronic articles and all of them will be more or less affected by the new European chemicals regulation REACH. The study objective was to clarify and disseminate how electronics companies will be affected by REACH and how the companies implement REACH. The project included the following activities:
The project activities were carried out in the period from October 2006 – March 2008. The activities were carried out by the following Danish electronics companies: Bang & Olufsen A/S, BB Electronics a/s, Dantrafo Horsens A/S, GPV Group A/S, Grundfos A/S and OFS Fitel Denmark ApS in collaboration with ITEK, DI and DHI. Through bilateral meetings with the individual companies and five joint ERFA sittings, work was done to clarify the roles of the companies under REACH, mapping of chemicals, assessment of whether articles contain substances that potentially require authorisation, contact to suppliers and strategies for the implementation of REACH. The accomplishment of the case studies was one of the main activities of the project. They opened up the possibility for the companies of experiencing some of the consequences of the regulation to their companies. Two case studies were carried out:
Five of the companies participated in the case study with the supply chain, which was built up around a fictive article - the telephone BeoCom XX. Each company produced an article that formed part of the fictive telephone. As the companies formed part of the same supply chain, they had to communicate with each other during the case. The project participants who mainly belonged to the environmental departments of the companies also had to communicate internally in their own companies in order to procure information on chemicals consumption for the production of their own article, information on purchased articles, contact persons at the suppliers etc. The result of the chemicals mapping showed that, among the chemicals used, there were substances of the type that may be included in the Chemicals Agency’s candidate list of substances that potentially require authorisation. However, the concentrations in the articles of the case were not of a magnitude (< 0.1 weight percentage) that will result in any obligations for the article producer to supply information on the substance to customers7 or to notify the Chemicals Agency. At one of the companies, a specification of the number of articles purchased showed that the number of different articles used in the production of a new article might exceed 1000. This means that this company has more than 1000 articles to take into consideration when assessing their obligations as article producer. Communication to external suppliers of chemicals and articles was tested in both case studies. The chief purpose of the communication was to make the suppliers state whether they would fulfil their obligations under REACH. Another aim was to attract attention to REACH and to establish contacts with suppliers that may constitute the basis of future cooperation. The communication was made by forwarding letters with checklists, telephone conversations and one of the companies had a meeting with their American supplier of an essential chemical product. The supplier’s safety data sheet did not contain the exact composition of the product and, on a previous occasion, the supplier had not been interested in giving any information on the composition. The meeting with the supplier revealed that he was familiar with REACH and planned to establish an only representative in the EU. The second case study focussed on the framing of letters for suppliers and information to customers. A large part of the work consisted in defining the form, in which the information should be returned from the suppliers for future registration in the internal data system of the company. The general experience showed that it was extremely difficult to start the ball rolling, especially with article suppliers. An essential factor was their ignorance of REACH and their new obligations. A closer analysis of the communication with chemicals suppliers showed that it was primarily the manufacturers of pure chemical substances and major producers of chemical products who responded quickly. When the agent or sub-supplier was placed far down the supply chain, it was much more difficult to get the communication process going. Working with the case studies showed the need for cross-organisational work and experience shows that the implementation of REACH is not only a task for the environmental department. It is necessary that management is involved and that work is made across the organisation. The experience and results of the project were disseminated through a seminar with participation of approx. 60 Danish electronics companies and through the setting-up of a website hosted by ITEK, DI ( http://itek.di.dk/Mit+fagomraade/Elektronik/REACH/). The website was developed in the project and contains text and video recordings with interviews of representatives from the participating electronics companies. Conclusion and recommendations Apart from the role as article producer, all participating companies could add the role as industrial user of chemical substances. Both roles belong to the group of downstream users under REACH. A downstream user of a chemical is under obligation to apply the chemical in compliance with an enclosed safety data sheet and a potential exposure scenario. A downstream user is entitled to inform his supplier of his application of a chemical. Electronics companies using a chemical in a way unknown to the industry are recommended to inform their supplier. Alternatively, the company may decide to make its own chemical safety assessment for the particular application of the substance. The majority of the participating companies turned out to be article importers as well. The article importer and the article producer are under the same obligation to provide information to customers on articles containing substances of very high concern that may occur in their articles and also from June 1st 2011 to notify the Chemicals Agency about such substances. Substances of very high concern are included in the candidate list of substances for eventual inclusion in the authorisation procedure, published on the ECHA website8. Electronics companies importing or producing articles are recommended to prepare a policy and strategy for their information retrieval regarding potential candidate substances in their articles, i.e. CMR1-2 substances9, potential PBT10 or vPvB11 substances and substances with endocrine disrupting effects. The electronics industry already has a good deal of experience in collecting information from companies outside the EU. Experience gained during the implementation of the RoHS Directive. The electronics industry is recommended to gather and analyze this experience with the purpose of preparing a manual for the similar implementation of REACH. The manual may a.o. include proposals for prioritizing the efforts of the company, information on which articles may contain hazardous substances, letter templates and methods for substitution of substances of concern. Finally, the project showed that at least one of the participating companies had the role of importer of chemical substances. If the exporting company establishes an only representative in the EU, this only representative will take over the obligations of the importer. This means that this only representative will be in charge of the registration of the substance and the electronics company becomes downstream user of the substance in question. If, however, the exporter does not establish an only representative in the EU, the importing electronics company itself is under obligation to register the substance when the imported amount is one or more tons a year. Therefore, it is recommended that the individual electronics companies form a general view of the purchased chemicals and of whether the company will be under any obligations as an importer. [7] Please beware that this interpretation may not be correct when taking the dissenting wievs of DK and five other MS into account. Se:http://guidance.echa.europa.eu/guidance_en.htm [9] CMR1-2: Carcinogenic, Mutagenic, Reprotoxic - categories 1 and 2 [10] PBT: Persistent, Bioaccumulative, Toxic [11] vPvB: very Persistent, very Bioaccumulative
|