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Difference between IMDS, RoHS, REACH-SVHC, Material composition declaration certs.

Kales Veggie

People: The Vital Few
#11
Re: Difference between IMDS, RoHS, REACH-SVHC, Material composition declaration certs

First - thanks for a good discussion!
The DDT comparsion is a superb comparsion...REACH is for EU (correct me if I am wrong), the DDT ban was or became an international agreement (more or less).
REACh will / has a worldwide impact. The substances that will go on the Authorisation list later this year, will more than likely disappear from the market. That is why companies should pay attention to REACh. Many countries and the UN are developing their own regulation or are following REACh (e.g. Turkey). A new product similar to DDT will likely not be sold in today's world.

So are we good stewards? I eat meat, drive my car, travel with a airplane to Egypt on holiday, work for a supplier to the automotive industry, buy imported products from China - calculate the CO2 emissions that I am responsible for - so I am obviously not a good steward...are any of you?
We are becoming better stewards by learning more and become more aware of the impact that we have on "mother earth". We all remember the acid rain in Sweden that killed the lakes (I grew up in the Netherlands).

Before REACH there were regulations, I don't know how in-/effective they were? Please tell me Kales if you know.
ELV and TSCA (USA EPA). CAA and CWA which helped clean up the Great Lakes (between the US and Canada), come to mind. Of course there are big differences between these law/regulations since they are addressing different things.

Of course REACh is a completely different approach. Here in North-America, we now have the Canadian Challenge List and the California Green Chemistry Initiative. Also two states (Oregon and Washington) have banned lead wheel weights and are considering banning Copper in linings of brake pads. The old TSCA law is being rewritten. EPA has increased its activity level since Obama became president.

By the way, how many are performing a MET matrix or type of LCA?
No, I have not, but have done a similar reporting for a government body.
 
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A

Aimee

#12
Re: Difference between IMDS, RoHS, REACH-SVHC, Material composition declaration certs

Jonazz,

While this should be about the environment, after seeing some of the CLP submissions, I'm not so sure. One would expect that evidence used to "prove" a chemical is hazardous would be well done. I had the opportunity to read through a submission dossier for a chemical to be classified as a skin irritant. Any of the studies that showed that the specific chemical in question was not an irritant were discounted as being bunk. Meanwhile, they had some "great" studies that showed similar chemicals were skin irritants. When you read the actual study, the author basically concluded that since they thought the chemical was an irritant, even though the evidence was not conclusive, it must be an irritant.

I'm not against restricting hazardous substances; I'm very sensitive to the chemicals I bring into my home and I try to live a relatively green lifestyle, but I think that the pressure from both sides, industry and environmentalist on this issue prevents the political folks from finding the truth of the matter that seems to be somewhere in the middle. Substituting an unproven chemical in a process for a known one does not solve the end-of-life issues with substandard burn processes for disposal.

Back off the soap box. No matter what specific industry your company is in, for manufacturers it is critical to be aware of the rapidly evolving regulatory picture for chemicals for the countries where product is shipped and manufactured. The supply chain must be controlled, a system must be available for storage of data (unless you're a very small company it is easy to be overwhelmed by data).
 

andka907

Involved In Discussions
#13
Re: Difference between IMDS, RoHS, REACH-SVHC, Material composition declaration certs

Kales

Need your expertise
Today I read a proposal that Chromium trioxide will be put on the SVHC list.
Please see link

http://echa.europa.eu/doc/press/pr_10_16_svhc_consultation_20100830.pdf

Have you also read this?

How will this impact all the surface treater that just changed from Cr6 due to the ELV?

--------------------
I live in Sweden so the polution is still valid but not only in Sweden, maybe the focus was from here, just take a look at the pine forrests and see how they looks and compare to a (rel.) healthy pine forrests far away from the civilisation.
Now we have more disussion regarding the lakes, too much fertilization from agriculture industry.

Then it is good, if REACH will also be applicable for US, China etc...only if it will not be another different system in US or other states (like our fellow OEM customers who likes to have their own different specific demands or worse test methods on same issues)

I understand that Canada and Sweden are two countries very focused in environmental issues and wants to be in the front. I hoped that Kyoto and Copenhagen should have been more effective because, as you also have stated, there are several good examples where regulations have been a success international and almost world wide. (Phase out of Freons, DDT etc)


BR
 
B

Badrul

#14
Re: Difference between IMDS, RoHS, REACH-SVHC, Material composition declaration certs

here's a link that can help to understand on IMDS vs RoHS.
www(.)rsjtechnical.com/IMDSvsRoHS(.)htm
 

SpinDr99

Involved In Discussions
#15
Thanks for all of this information, but my problem is quite different. I need guidance because I work for a distributor of electronic components servicing the aerospace and military segments. We only buy and re-sell. No assembly, no testing. Buy and re-sell. Our purchases come with a certificate of compliance. Chemicals or elements which make up the devices are not stated.

So HOW do I find those out, and determine which are SVHC's? AND, since these are relatively small components (the largest being integrated circuit chips), is it safe to assume NONE of the products we re-sell are above the content threshold? IF that's the case, can we simply come out with a statement that none of the items sell are above the threshold, and we don't need to report each and every element/chemical are in products we re-sell?

I'd REALLY appreciate any input from people in the electronics industry. THANK YOU!!!!!!!!
 
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