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How to Make Electronics That Meet REACH Regulations

Through the years, the global PCB manufacturing industry has undergone numerous changes. Some of these changes have to do with rules and regulations. One of the recent developments in the area pertains to REACH compliance. Manufacturers of all electronic products need to pay close attention to these requirements so their products meet the necessary quality and safety standards.

Unfortunately, most electronic suppliers and consumers are unaware of what REACH is or the importance of REACH electronics compliance. It’s why we prepared this professional guide to provide this essential information.

In this comprehensive guide, you’ll learn everything you need to know about REACH.

 An engineer developing a microelectronic processor

1. What is REACH?

REACH is an acronym for Registration, Evaluation, Authorization, and Restriction of Chemicals. It’s a regulation of the European Union that came into force in June 2007.

REACH’s primary purpose is to enhance people’s health and safeguard the environment from risks that result from chemicals. REACH also aims at promoting the competitiveness of the chemicals industry throughout the EU. The regulation also encourages other hazard assessment methods to minimize the need for performing such tests on animals.

But does REACH only concern itself on only chemical substances in industrial processes? No. In principle, the regulation applies to any chemical substances, including those consumers use in their daily lives. These include chemical substances in paints, cleaning products, furniture, electrical appliances, and clothes. For this reason, REACH has an impact on almost all companies.

REACH expects companies to take responsibility by identifying and managing risks relating to the substances they produce and market in the European Union market. These companies must demonstrate how consumers can use these substances safely. Besides, they have to communicate any risk management practices consumers need to put in place.

What if it’s impossible to manage the risks from the substances? Then authorities need to restrict the use of these substances in various ways. Ultimately, the goal is to substitute highly hazardous substances with less dangerous options.

A young apprentice working in an industrial company assembling electronic components in the mechanical engineering of a modern factory

REACH

2. How Do You Comply With REACH?

Companies have a variety of ways to comply with REACH requirements. These include:

Data Verification and Consolidation

One of the biggest challenges companies face in complying with REACH is cleaning and validating data. When data arrives from suppliers, it usually has a variety of problems. These include:

  • A mismatch between the chemical substance name and the CAS number
  • Missing or incomplete CAS numbers
  • Two or more substances using one CAS number
  • Two or more supplies using different names or CAS numbers to refer to the same substance

To resolve the above problems, it is necessary to cleanse and consolidate the data as you receive it from your suppliers.

It is essential to comply with REACH electronic requirements

Comply With REACH

Establish a Chemical Substance Database

Another way to comply with REACH electronics standard is to develop a chemical substance database that’s enterprise-level. This database must include all the components you use to create your products. 

The best way to create such a database is to install a reliable software system. The software can roll up chemical substance data from different homogenous materials. The course will also calculate data at different levels, from the component to the assembly to the product levels. The software system also facilitates the correct reporting on specific substances, including SVHC and CMR substances at both levels and across various products.

Given that a chemical substance database covers potentially tens of thousands of different components, entering such amounts of data by hand would be unfeasible. Doing so would be time-consuming and might introduce errors. Neither can a spreadsheet application such as MS Excel handle the requirements of such a database. Moreover, it would be unrealistic to ask your suppliers to send data on chemical substances in a standard format for your software to identify. Hence, it would help if you found the right way of adequately entering the data into your software system.

REACH Compliance of Data Collection

Data collection in your manufacturing company is one of the essential parts of REACH compliance

REACH Compliance of Data Collection

Perhaps the biggest obstacle in managing REACH electronics compliance is discovering the exact chemical composition of each component and material in your products. Once you have complete knowledge of all the chemicals in your products, you can develop a compliance plan for both the short and long-term.

The biggest challenge is to get suppliers to provide all the information on chemical substances. It’s both a resource-intensive and tedious process. It requires you to make countless phone calls or send numerous emails. Your suppliers may not understand all the aspects of regulations, including SVHCs. Sometimes, the supplies demand to know the rationale for providing this information.

Your job is to request suppliers for the full disclosure of substance data at all times. Ideally, your supplies need to inform you every time they’re using SVHC levels above 0.1 percent in concentration. It is dangerous for you to fail to pursue this information.

Limited Resources

The majority of electronic manufacturers do not have a specialist in chemical management. Many of them devote REACH electronics compliance to either the quality assurance group or the component engineering department.

Product designers do not need to understand the various chemical substances in components. However, they need to know whether these components are compliant to REACH requirements.

Given that many companies have a limited budget and few resources, they only hire a few professionals to take responsibility for REACH reliance. Implementing the latest modules and upgrades on REACH compliance can require hundreds of thousands of dollars or more. For many companies, spending these amounts of money is beyond reach.

So, what should you do?  The solution is to look for creative ways of implementing REACH compliance requirements using the budget and resources you have.

3. Is REACH Mandatory?

Every company that exports electronic products to the European Union must have the authorization and requirements that meet REACH chemical compliance. If your company doesn’t adhere to REACH regulations, chances are you’re already out of the EU market. Whether meeting the requirements of this regulation is essential to you or not depends on your company’s goals.

There are penalties for violating REACH requirements. These violations vary from country to country.

If you are an electronics supplier, choose a contract manufacturer who can advise on how to determine whether you are REACH compliant or not. A reputable PCB design partner can inform you of all the risks and alternatives. 

There are PCB designers and assemblers who use third-party tools to help customers determine whether the components in their electronics are compliant or not. You can also take advantage of available tools to verify whether the products you’re producing for the European Union market are REACH-compliant.

REACH electronics standards are mandatory for companies to access the EU market

4. Best Practices for Compliance Management in REACH

4.1.Clean Up the BOM

The majority of BOMs tend to be dirty. That means that they contain names of manufacturers that are inaccurate or incomplete numbers.

Before you start to call your suppliers for data on chemical substances, you need to clean up dirty BOMs in the PLM or ERP. The chances are that you already did it a long time ago when you requested RoHS data from your suppliers. If you didn’t, now’s the time to do it. You can clean all BOMs by validating manufacturer names, part numbers, and part descriptions on every BOM component. Scrubbing your BOMs saves you a lot of time when it comes to getting data from suppliers.

4.2.Collect All Public Chemical Substance Information

To meet REACH electronics compliance requirements, it’s essential to fully know all the components’ chemical composition in your electronic products. That’s why you need to collect full-disclosure data of the chemical substance from suppliers. Even if you only produce articles and need only REACH SVHC compliance, collecting this data is still paramount.

Of course, you can still collect REACH SVHC certificates. But these certificates are only useful for six months to one year. You’ll need to add new substances to the SVHC Candidate List regularly. By collecting full-disclosure information on chemical substances, you won’t need to go back to the same suppliers for original certificates whenever the news on your list changes.

Data collection tends to be the most challenging part of REACH-compliance. If it is financially viable, consider outsourcing the task to a competent third-party solution provider. By outsourcing to the right partner, you may find that the job becomes faster, more accurate, and cheaper. Outsourcing also makes it possible for your designers and engineers to dedicate their time to their core tasks, which improves productivity.

4.3.Appropriate Software Tools Help Analysis

As soon as you begin collecting data on your suppliers’ chemical substances, you’ll need the right software to manage the data collection activities. The tool is also necessary for establishing your internal chemical substance database. Furthermore, this software helps in the analysis of the substances in your products.

Using the software, you can tell which data you have already collected and which you haven’t. The program also provides you with information about the total weight of chemical substances in the product based on the items you are shipping to the European Union each year.

Your software reports any SVHC chemical substance in components you used in products. This way, you can inform your suppliers if you need replacements. Likewise, you can alert your clients to the correct usage scenarios.

If there’s more than 0.1 percent of SVHC substance in products, notify the European Chemical Agency (ECHA). It is especially the case if you ship over a ton of products per year.

While the software is indeed beneficial, there are specific problems you may encounter when using it. For instance, you may find that the chemical substance’s name is the same, the single CAS different, but it all belongs to the same meaning. Another scenario involves the limitations of merging substance data. Other issues include consolidated maintenance difficulties and compressed substance master data.

Adhering to REACH best practices can help you stay compliant

4.4.Establishment of Internal Chemical Substance Database

During the process of data collection and validation, companies need to develop an internal substance database. You do this by entering the data you collect into the software system you’re using.

One of the challenges you need to prepare for involves the data format. Generally, your suppliers will provide data in different formats. These include Excel, PDF, HTML, and XML. It’s your responsibility to consolidate these formats into a standard format so that you can import them to your software system. Where you’ve outsourced data collection to a third-party solutions provider, request them to provide you with a common format that you’ll be able to import to your software tool.

4.5.Make Compliance Changes to Components

In case you discover that the components in your BOM contain certain substances that REACH regulates, inform supplies for replacements. Most reputable suppliers will oblige. If yours fails to offer you a clear plan for replacements, consider changing suppliers. It Helps you stay compliant and avoid disruption of your business.

5. What Is the Difference Between Reach and RoHS?

RoHS is an acronym that stands for Restriction of Hazardous Substances. It’s an EU directive instead of being a regulation like REACH is. National Measurements Office (NMO) enforces this directive.

The primary purpose of RoHS is to solve the increasing global problem of consumer electronics waste. As technology continues to evolve, consumers dispose of more electronics. These electronics end up in landfills worldwide as electronics landfills grow both in size and number, human health and environmental hazard increase.

RoHS pertains to the manufacture of different types of electronics and electrical equipment. These products are without the use of the following hazardous materials:

  • Lead (Pb)
  • Cadmium (Cd)
  • Mercury (Hg)
  • Polybrominated biphenyls (PBB)
  • Hexavalent chromium (Cr6+)
  • Polybrominated diphenyl ether (PBDE)

Some of the standard equipment RoHS applies to include:

  • Large and small household appliances
  • Consumer equipment
  • IT and Telecom equipment
  • Lighting equipment, such as light bulbs
  • Electronic and electrical equipment
  • Medical devices
  • Toys, sports, and leisure equipment
  • Automatic dispensers
  • Monitoring and control tools
  • Semiconductor devices

Whether you manufacture a product within the EU or export it, it’s your responsibility to comply with RoHS requirements. That’s why most companies require their manufacturing partners to be RoHS compliant before buying them. It’s the best way to maintain compliance throughout the assembly process.

  • The REACH is an EU regulation that addresses chemical substances’ production and usage, as we pointed out earlier. REACH also focuses on the potential effects of these substances on people and the environment.
  • Requires every company to manufacture or import products with chemical substances into the EU to register with ECHA.
  • REACH demands that all manufacturers, importers, and suppliers communicate necessary chemical substances throughout their supply chain.

This way, everyone remains aware of the information relating to the health and safety of the products.

According to REACH, the chemicals that of high interest include:

  • Mutagens
  • Carcinogens
  • Persistent, bio-accumulative, and toxic chemicals
  • Reproduction toxins

The primary difference between REACH and RoHS, therefore, is that. In contrast, RoHS bans chemical substances in electrical components within the directive, and the REACH focuses on all chemical substances, including those manufacturers use to make the product. These include substances consumers use in their day to day lives, such as solvents, paints, and more. In short, REACH is like RoHS on steroids.

Both RoHS and REACH are essential in the manufacture of electronics

6. Do All Electronic Products Need to Meet Reach Electronic Standards?

REACH compliance is mandatory for any company that wants to sell electronic parts in the EU region. Of course, there are many additional perks when you comply with REACH beyond the permission to get your products into the European Union market. 

Most countries you may want to sell to also have regulations that are similar to REACH. By being REACH -compliant, you can sell to these markets as well.

REACH electronics standards are essential for all electronics companies

7. REACH Exemption

For manufacturers and suppliers outside the EU, REACH requirements do not bound you. It includes people who wish to export their products to the EU region. Generally, the responsibility lies with the importers within the EU.

In some instances, REACH responsibilities apply to downstream users as well. If you handle any chemical substances during the manufacturing process, it’s best to check your obligations. There may be specific exemptions about the chemical substances you or your manufacturing partner use during the manufacturing process.

Even if your company is outside the EU, it helps to follow REACH developments for restrictions and bans. These developments could affect the design of your electronics as well as your manufacturing decisions. You don’t want to risk any of your products breaking REACH standards, especially if you aspire to sell to the EU.

8. The Impact of REACH on Electronics Companies

REACH electronics regulations impact a large variety of companies across numerous sectors. Some of these companies may not even think that they deal with chemicals. Under REACH standards, companies may have one or more of the following roles:

a. Manufacturer Impact

Companies that manufacture chemicals are most likely to have essential obligations under REACH. It applies to you whether you produce chemical substances for yourself or supply them to consumers.

b. Importer Influence

Companies within the EU that buy products from outside the EU are highly likely to have REACH obligations. Whether you import individual chemical substances, mixtures of chemical substances for onwards sale, or even finished products such as furniture, plastic goods, and clothes, REACH will impact you.

c. Impact on PCB Companies

Printed circuit boards (PCBs) are an integral part of electronic and electrical products. As a result, PCB manufacturers, assemblers, and suppliers are under direct responsibilities under REACH.

d. Downstream Users

Countless companies use chemical substances in their day to day operations, even without realizing they do. If you usually handle any chemical substances in any professional or industrial activity, check your REACH obligations.

REACH electronics compliance affects various types of industries

SUMMARY

As an electronics manufacturer, assembler, or supplier, you want to access as many markets as possible, including the lucrative EU market. One of the most important ways to do so is by being REACH-compliant.

Understanding REACH electronics requirements is crucial to a successful marketing run in the EU, especially if your company is within the region or sells products there. But even if you are outside the EU region or don’t usually export your products there, being REACH-compliant has its benefits. That’s because most other markets will still have regulations that are similar to REACH. Meeting these requirements is your first step to accessing these markets.

Ultimately, if you deal with electronics, you aren’t immune to REACH standards or penalties, no matter your location. Incorporating these requirements into every safety compliance program in your organization is the best way to keep your sales running.

Remaining REACH-compliant requires working with a PCB manufacturer who is compliant with this regulation as well. We boast a long history of providing PCB products of the highest quality to our customers worldwide. We go above and beyond to ensure that all our products meet all REACH standards and other regulations. Contact us today to see how our products can contribute to the success of your company.

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Hommer Zhao
Hi, I am Hommer, the founder of WellPCB. So far, we have more than 4,000 customers worldwide. If you have any questions, you can feel free to contact me. I really appreciate any help you can provide.

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