Are E&E Products Affected by REACH?

All electrical and electronic equipment contain chemical substances. They can be part of or found in fabric, plastic, metal, ink, paper, wood, or glass components. As a result, the substances in E&E products come under the scope of the new European REACH regulation.

The European “REACH” Regulation No 1907/2006 on the Registration, Evaluation, Authorization and Restriction of Chemicals entered into force on June 1, 2007. It aims to strengthen the protection of human health and the environment against chemical substances. Under REACH, producers, importers and downstream users have various obligations. Depending on one’s specific role under REACH, this may include pre-registration, registration, authorization and/or notification of substances, as well as communication along the supply chain about their use in preparations and/or articles.

How is E&E Affected?

The main parts of REACH that affect E&E equipment include:

  • Registration
  • Management of Substances of Very High Concern (SVHC)
  • Registration

A major part of REACH is the requirement for manufacturers or importers of substances at or above one ton per year to register the substances with a central European Chemicals Agency (ECHA). A registration package must be supported by a standard set of data on the substances. If they do not register their substances, then the corresponding data will not be available and as a result, they will no longer be able to manufacture or supply them legally. In other words, no data, no market.

This will Apply to:

1. E&E equipment categorized as containing preparations:

  • Oil with clipper set Ink or toner in printer cartridge
  • Electric air fresheners
  • Gel with electric massager
  • Wax with wax heater
  • Silica gel sachets
  • Raw materials used for manufacturing (alloys, solder, paints, adhesives)

2. E&E equipment categorized as containing articles with intended release of substances:

  • Scented components
  • Scented products, e.g. scented electronic candles
  • Substances of Very High Concern

Some substances contain hazards that have serious consequences, that is, they may cause cancer (carcinogenic), or they have other harmful properties and remain in the environment for a long time (persistent) and gradually build up in animals (bioaccumulative). These are ‘substances of high concern'. One of the aims of REACH is to control the use of such substances via authorization and restriction and to encourage the industry to substitute them for safer ones.

Notification, Authorization, Restriction

EU importers will be required to notify ECHA if SVHC from the candidate list are present in articles at specific concentrations at or above one ton per year. EU importers or manufacturers may also require authorization when SVHC is present in preparations. REACH will also regulate certain substances by setting conditions such as limit requirements.

Communication in the Supply Chain

The passage of information up and down the supply chain is a key feature of REACH. Manufacturers and importers should provide users with information on the dangers involved with the chemicals and how to control such risks. This applies to finished consumer products, components and packaging that contain SVHC from the candidate list.

You can market quickly and easily by ensuring that your products do not contain harmful substances. Learn more about REACH.

For more information, please contact:

Lauren Conroy
REACH Business Development and Consultant

SGS United Kingdom
t: +44 20 8991 3406

 About SGS

The SGS Group is the global leader and innovator in inspection, verification, testing and certification services. Founded in 1878, SGS is recognized as the global benchmark in quality and integrity. With more than 56,000 employees, SGS operates a network of over 1,000 offices and laboratories around the world.