Registration of the substances used along the supply chain
The introduction of the REACH regulation brought in its wake new duties and responsibilities in substance management and supply-chain management. Manufacturers and importers not only have to comply with legal requirements, they also need to implement a compliance system. These systems include voluntary elements that help manufacturers and importers to save costs.
Why do substances used in the supply chain and in the process have to be registered? The reasons can be manifold:
- Customer-related requirements
- Customer requests
- Ensuring long-term deliverability
- Legal requirements / public interest
- Building know-how or innovation:
- Which substances does a product comprise?
- Which substances do I need to manufacture a product?
How does substance management work in practice?
REACH includes communication requirements to ensure better communication in processes. Step one aligns your internal organisation to these requirements, as substance management applies to all departments within the sourcing process.
Step 2 then uses the Bill of Material (or BOM) to ensure the internal linking of mixtures, articles and other materials up to the finished product. Our experienced REACH experts will be at your side throughout all these phases and along every step of the way.
What are the benefits of substance-based supply-chain Management?
Substance-based supply chain management is introduced to ensure safety and compliance along the entire supply chain, as more and more substances are subject to authorisation and/or identified as a SVHC. However, manufacturers are frequently unaware whether their products include parts with SVHC or substances that require authorisation. Where complex products are concerned in particular, there is frequently insufficient knowledge of the individual parts used in the production. The 0.1% threshold defined in Article 33 provides a false sense of security.
Substance-based supply chain management covers not only the requirements of the REACH regulation, but also those laid down in the RoHS Directive, requirements of third countries or requirements concerning conflict minerals etc. After all, the following may apply:
- A substance may be prohibited
- Use of a substance may be restricted
- There may be a duty to communicate information on a substance
- A substance may have a negative Reputation
- A substance may have only limited availability
- Without a certain substance, a business model may fail
- Use of a substance may have to be deliberately avoided
- A substance may fall into one of the above categories in the near future
Be on the safe side. We implement substance management tailored to your needs.
Restrictions in articles (Bill of Material)
Authorities throughout the EU are checking an increasing number of articles, primarily consumer products. Products that are not in compliance with the comprehensive regulations on substance restriction are taken off the market. Avoid financial loss and protect yourself from liability risks and loss of reputation. Importers face particularly high risks.
Based on the large number of substance restrictions applicable to articles, full knowledge of the composition of your product is imperative. A Bill of Material or Full Material Declaration shows whether your product includes restricted substances as defined in Annex XVII to the REACH regulation and, if so, in what concentrations. Use a Bill of Material to avoid the unintentional placing on the market of illegal products. Our REACH experts will be happy to assist you with the preparation of such a BOM. Talk to us!