REACH - Candidate List Substance vs. Authorisation List Substance in EEE

W

Winterheart

#1
Hello,

I've recently started investigating certain small EEE manufacturer's compliance with REACH Regulation and got somewhat stuck.

Equipment manufacturer is based in EU but imports some spare parts from outside EU. Spare parts supplier claims they check that raw materials they use all contain less than 0.1 % of any of the Candidate list substances, so naturally it's even less, sometimes significantly less in finished articles. Total amount of substances imported is well below 1 ton. So manufacturer has no obligations with respect to SVHC and apparently no obligations under REACH at all at the moment.

However, some of the substances in question are now included in Authorisation list and their sunset date is coming. I'm not sure if it changes anything for us.

Is there a different maximum allowable concentration for Authorisation list SVHCs?
How should we demonstrate we are not importing or selling any of these substances? Currently we have REACH compliance box ticked in specifications from spare parts suppliers and they are eager to provide test results for raw materials. Do we need to test for all SVHCs from Authorisation list, or only those past their sunset dates or is some statement from raw materials manufacturer that these substances were not intentionally added to the product enough?

I feel completely overwhelmed by the page count of REACH and all the guidelines, and the more I read the more confused I feel. Hope I can get some answers or directions on where to look for the answers here :)

Thanks in advance :2cents:
 
Elsmar Forum Sponsor
W

Winterheart

#2
Ok, I have contacted ECHA and got my answer:

The placing on the market or the use of an article which contains an Annex XIV substance is not subject to the authorisation requirement. However, if not specifically exempted otherwise, the incorporation of an Annex XIV substance into an article is a use which is subject to the authorisation requirement.

So those importing spare parts from China should only worry about Candidate list :)
 
Thread starter Similar threads Forum Replies Date
I REACH - New SVHC list? New substances to be placed on the candidate list? RoHS, REACH, ELV, IMDS and Restricted Substances 5
chris1price REACH SVHC Candidate List & DEHP (Di(2-ethylhexyl) phthalate) RoHS, REACH, ELV, IMDS and Restricted Substances 1
P How far an operator can reach into a machine before it becomes an ergonomic problem CE Marking (Conformité Européene) / CB Scheme 5
M EU – REACH Authorisation Decisions List REACH and RoHS Conversations 0
M EU – Chemical Safety Report – CSR – REACH Authorisation decisions – Triton X-100 – Ortho-clinical-Use1 REACH and RoHS Conversations 0
Nicole Desouza Who has to be compliant with REACH Declarations? REACH and RoHS Conversations 11
J Where can I find the latest update to Reach and ROHS? REACH and RoHS Conversations 7
padraick63 REACH and ROHS Requirement for a Molded Part REACH and RoHS Conversations 1
R Certificate of compliance to RoHS/REACH/WEEE - any such animal? REACH and RoHS Conversations 18
T MSDS Language Requirements for Reach Purposes REACH and RoHS Conversations 3
S IMDS=REACH for automotive industry? REACH and RoHS Conversations 2
L REACH Compliance - Small, family-owned contract manufacturer REACH and RoHS Conversations 16
R REACH and ROHS compliance for hundreds of parts made over 25 years REACH and RoHS Conversations 3
P REACH - BOMcheck.net - What I can expect from this service? REACH and RoHS Conversations 0
P REACH - A few of the hundreds components in my product no longer meet requirement REACH and RoHS Conversations 2
C SVHC Lead - Communicate in the supply chain under Article 33 of the REACH Regulation REACH and RoHS Conversations 1
D How do I show compliance to RoHS, REACH and Conflict Minerals? REACH and RoHS Conversations 6
J RoHS, WEEE and REACH Consulting Expertise Needed REACH and RoHS Conversations 4
P Necessary Compliance Documentation for RoHS and REACH REACH and RoHS Conversations 5
M ROHS & REACH in TEFLON Material - NABL Testing Laboratories REACH and RoHS Conversations 1
N Taking exception to REACH Requirement - Appropriate Language REACH and RoHS Conversations 4
H REACH Registration Requirements - Who is required to Register REACH and RoHS Conversations 1
dubrizo Who handles Your Reach, RoHS, 3TG Compliance RoHS, REACH, ELV, IMDS and Restricted Substances 9
smryan Compliance Officer Outsourcing? RoHS, REACH, ELV, GADSL, IECSC Other ISO and International Standards and European Regulations 5
R How to demonstrate REACH Compliance RoHS, REACH, ELV, IMDS and Restricted Substances 3
N How do I demonstrate REACH compliance ? RoHS, REACH, ELV, IMDS and Restricted Substances 1
M Medical devices are CE mark but not sold in EU - Need to comply with REACH? RoHS, REACH, ELV, IMDS and Restricted Substances 9
Q REACH due dilligence and meeting the ever moving SVHC target RoHS, REACH, ELV, IMDS and Restricted Substances 5
L IOS-MAT-0010 vs REACH/ROHS RoHS, REACH, ELV, IMDS and Restricted Substances 2
P Law restrictions in each country [REACH, CONFLICT MINERALS, Canada Gazette] RoHS, REACH, ELV, IMDS and Restricted Substances 2
E IFU Changes - How it is ensured that IFU changes reach Surgeons EU Medical Device Regulations 4
P Service Part Issues - Request for MDS and REACH Declaration RoHS, REACH, ELV, IMDS and Restricted Substances 3
A Start Compliance to RoHS, SCHV and REACH RoHS, REACH, ELV, IMDS and Restricted Substances 10
I REACH Certificate of Compliance Manufacturing and Related Processes 2
J Anyone using SiliconExpert Technologies Software for RoHS/REACH/CM RoHS, REACH, ELV, IMDS and Restricted Substances 1
S Chinese / English Language REACH Statements RoHS, REACH, ELV, IMDS and Restricted Substances 4
J RoHS/REACH Compliance Tools and PLM Integration RoHS, REACH, ELV, IMDS and Restricted Substances 14
S Does Australia/New Zealand require RoHS, WEEE, REACH and EMC? RoHS, REACH, ELV, IMDS and Restricted Substances 4
Brizilla Is 303 SS (sus 303) Reach Compliant? RoHS, REACH, ELV, IMDS and Restricted Substances 4
B REACH & ROHS Declaration for Concrete Casting Water Feature RoHS, REACH, ELV, IMDS and Restricted Substances 3
N Off Shore Supplier PCBA REACH Reporting RoHS, REACH, ELV, IMDS and Restricted Substances 4
quality1 Charging Customers for REACH Documentation RoHS, REACH, ELV, IMDS and Restricted Substances 8
R Ppk vs Cpk: Big Differences - What conclusion can I reach about my process? Six Sigma 3
V Worker Chemical Safety Assessment - CEFIC/REACH Occupational Health & Safety Management Standards 0
O REACH Registration - Automotive Parts Manufacturer based in Morocco RoHS, REACH, ELV, IMDS and Restricted Substances 4
S Applicability of REACH Requirements RoHS, REACH, ELV, IMDS and Restricted Substances 7
T Is REACH applicable to Medical Devices in the EU? RoHS, REACH, ELV, IMDS and Restricted Substances 6
R Are you using software for REACH? RoHS, REACH, ELV, IMDS and Restricted Substances 7
F Making a REACH statement - Plastic Injection Moulding RoHS, REACH, ELV, IMDS and Restricted Substances 9
T Auditors Reach - FSC (Forest Stewardship Council) Certification Audit Nonconformance Internal Auditing 12
Similar threads


















































Top Bottom