Making a REACH statement - Plastic Injection Moulding

fraktion

Involved In Discussions
#1
Hello all.

When in strife, who do you turn to? Elsmar cove!

I wonder if anyone can help me. I've been 'handed' dealing with REACH. I am the QM for a plastic injection moulding company, ISO / AS9100. Customers are now asking for statements of compliance from us.

My question is. Is it enough, to obtain statements from the raw material suppliers that their products are compliant to REACH, therefore the finished article we make will also be compliant? Or can the process affect the article, such as mould release spray and so on.

None of our products are made to 'release' anything, they are just plastic widgets...so to speak.

Can i simply send the declarations from our raw material suppliers, to our customer with a statement saying "the articles we make for you are compliant with REACH...please see attached"


Your help would be greatly appreciated.
 
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fraktion

Involved In Discussions
#4
Hello Ajit. Thank you for the warm welcome! I've been a long time lurker, finally i feel the need to post!

Thank you for the link Somashekar. That's definitely something i need to look into. Of course, i'm looking for the 'quick fix' at the moment as i'm getting screamed at.
 

Kales Veggie

People: The Vital Few
#5
Hello all.

When in strife, who do you turn to? Elsmar cove!

I wonder if anyone can help me. I've been 'handed' dealing with REACH. I am the QM for a plastic injection moulding company, ISO / AS9100. Customers are now asking for statements of compliance from us.

My question is. Is it enough, to obtain statements from the raw material suppliers that their products are compliant to REACH, therefore the finished article we make will also be compliant? Or can the process affect the article, such as mould release spray and so on.

None of our products are made to 'release' anything, they are just plastic widgets...so to speak.

Can i simply send the declarations from our raw material suppliers, to our customer with a statement saying "the articles we make for you are compliant with REACH...please see attached"


Your help would be greatly appreciated.
REACh requires you to know what you ship out the door ("put on the market"). As a manufacturer you have to know comes out of your process.

Depending on your process, it is possible that the substances (chemistry) of the article are different than what you buy as raw material.

The responsibility is on you (and your company). (BOMCheck does not absolve you of that responsibility. You have to know what is in your product.)
 
J

Jonazzz

#6
Hello all.

When in strife, who do you turn to? Elsmar cove!

I wonder if anyone can help me. I've been 'handed' dealing with REACH. I am the QM for a plastic injection moulding company, ISO / AS9100. Customers are now asking for statements of compliance from us.

My question is. Is it enough, to obtain statements from the raw material suppliers that their products are compliant to REACH, therefore the finished article we make will also be compliant? Or can the process affect the article, such as mould release spray and so on.

None of our products are made to 'release' anything, they are just plastic widgets...so to speak.

Can i simply send the declarations from our raw material suppliers, to our customer with a statement saying "the articles we make for you are compliant with REACH...please see attached"


Your help would be greatly appreciated.
Actually, for REACH, there is no such thing as a quick fix.
I do understand that supplying your customer with a standard letter would be most convenient, but as already stated by Kales Veggie indeed you are responsible for what you put on the market.

On the other hand, asking for a "Declaration of Conformity" with your upstream suppliers, would only be valid for a limited period in time, as the Candidate List might get updated twice a year.
In other words, you would have to renew these kind of statements directly after each update of the ECHA SVHC List, and likewise you would have to update your customers as well on the presence of the newly entered substances.
Also notice that REACH does oblige you, to inform the next actor in the supply chain when your products do contain a substance from the Candidate List (over 0.1% w/w), from the moment the List is published.

I strongly believe that it is is within the philosophy of REACH that manufacturers also get understanding on the chemical composition of their materials.

So, a quick fix,...., I don't think so.
 

fraktion

Involved In Discussions
#7
I thank you all for your comments.

So really, i'm embarking on a massive mission to ensure everything we ship out the door has been tested? That is one monster undertaking...

If i can, for example, get a knowledgable 'plastics professional' to ensure that the heating and melting of plastic granules that have been REACH compliant confirmed, does not in fact alter their chemical makeup; therefore the creation of any new SVHC's does not occur. I am then ok to create a statement in line with what my suppliers have told me, and send the supporting documentation with the statement to the customer?

Otherwise, i will have to send every part we make out for testing? And then do it again every time the list is updated?

If that's the case, that could potentially kill the business.

Surely there is a better way for injection moulders?
 
J

Jonazzz

#8
I thank you all for your comments.

So really, i'm embarking on a massive mission to ensure everything we ship out the door has been tested? That is one monster undertaking...

If i can, for example, get a knowledgable 'plastics professional' to ensure that the heating and melting of plastic granules that have been REACH compliant confirmed, does not in fact alter their chemical makeup; therefore the creation of any new SVHC's does not occur. I am then ok to create a statement in line with what my suppliers have told me, and send the supporting documentation with the statement to the customer?

Otherwise, i will have to send every part we make out for testing? And then do it again every time the list is updated?

If that's the case, that could potentially kill the business.

Surely there is a better way for injection moulders?
Well, indeed, REACH has some consequences that (if done correctly) take a bit more time, than just asking for a declaration and rewritting this into a standard letter.

One way to understand what is in your products, is indeed through testing. But as you mentioned already, this will kill the business and also it is NOT required by REACH that each product ondergoes extensive testing.
Today the Candidate List contains some 47 substances, but by the end of 2012 it is expected to contain around 106 substances.

To understand what is in your products, you will have to set up a Supply Chain Communication tool, that allows you to interface with your upstream suppliers on the contents of chemical substances within the materials they supply to you.

So, indeed, if you would have some "plastic professional" input, they would be able to tell you something for all the substances that are in today (and might not be regulated by REACH).
BUT, you will need to have this input each time something changes in the legislation (update of the Candidate List, update of Annex XIV and XVII).

So you would be looking more for process than for a corrective action to handle your REACH obligations.
 

fraktion

Involved In Discussions
#9
Hello again all.

My apologies for the necropost, only i thought i could add to the discussion after speaking with one of the countries biggest plastic distributors. Hopefully the below advice can help others from a plastic moulding background:

"You don’t have to test any parts under REACH What you are hearing on this is incorrect

Plastics are not in scope of REACH at the moment
What is in scope is the upstream additives that go into making the plastics and these must be tested and registered by the upstream suppliers. Our supplier informs us of the materials REACH status by making formal statements, which are available to you

All you need to do is obtain REACH compliance statements from your supplier (ourselves) on the products you use and send these onto your customer. Similarly SVHC statements are available from ourselves and these need to be passed onto your customer. Your customer can then pass the statements onto their customers if needed

These statements are available on our website, or if the required documents are not there or you need any other REACH information, please send an e-mail to:

Your obligation is to supply the statements to your customer, as we are obliged to supply the same to you, our customer.

Understanding REACH is not easy and what an organisation needs to do is confusing, but there is no testing, just a requirement to obtain and pass on information"
 
J

Jonazzz

#10
@Fraktion:
The reply given by your supplier (I guess from the wording "our customer"), is correct and not correct.

The statement "plastics are not under scope", is actually too wide, as REACH states that "polymers" are not under scope, although the monomers within the polymer need to undergo the "Registration" obligation within REACH.
It is true that this "Registration" obligation needs to be performed by the manufacturer of the monomer, the so called upstream supplier.

Nevertheless, the products that are manufactured from the polymer raw material, will be categorized as "Articles" within REACH and therefore have the "Information" obligation that is nicely explained by your supplier as merely passing on information.

In a sence this is a valid statement, because REACH does require each actor in the supplychain to inform the next actor on the presence of Candidate List substances.

It is my personal opinion that you are not able to produce a valid REACH Declaration, unless you revise it each time the Candidate List has its update.
In other words, @ least 2 a year, you will have to update your REACH statements, including the newly added substances.

It is fact, that REACH does not oblige you to test for anything, but I can understand that testing of parts could reveal the presence of substances, although maybe not expected.

Just be concious on what you send to your customer and make sure that indeed the substances are not present in your products.

I guess that also some companies will make statements, just for the sake of the statement.
 
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