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Reporting REACH - Electronic components distributor

SpinDr99

Involved In Discussions
#1
Hi All,

I've recently joined a company who sends products to the EU and I'm in need of help regarding REACH. To be more specific, we're a distributor of electronic components and I'm not sure where to begin to determine how what we buy/re-sell has an impact on our customers since I'm sure there are many chemicals involved in their manufacture. After that, I can't find anything which guides me on how to report on REACH. I would greatly appreciate any and all help you can offer.
 
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#2
I'm in need of help regarding REACH. To be more specific, we're a distributor of electronic components
(Disclaimer: I have limited knowledge of REACH.) As a distributor, you will need to place requirements on your upstream suppliers to provide REACH documentation for each component they provide/manufacture. Then, you will pass that information along when you supply a component to your customer (I'm assuming you sell to other businesses and not to consumers). So, in this sense it is similar to collecting and passing along RoHS declarations. As I understand it, for your type of product, the primary concern are SVHCs (substances of very high concern...currently 211 of them):
Candidate List of substances of very high concern for Authorisation - ECHA

Reach Registration - who needs to register?
Registration - ECHA

Start here - Understanding REACH:
Understanding REACH - ECHA
According to this page, you fall into this category:
Companies established outside the EU: If you are a company established outside the EU, you are not bound by the obligations of REACH, even if you export their products into the customs territory of the European Union. The responsibility for fulfilling the requirements of REACH, such as registration lies with the importers established in the European Union, or with the only representative of a non-EU manufacturer established in the European Union.
So, if that is case, your obligations will be to provide the EU-based importer with the substance information (such as SVHCs) that they will need to fulfill their REACH obligations.
 
#3
All declarations must be made by a legal entity established within the EU/EEA. If you are not one then either your importer needs to be responsible or you need to set up a formal Authorised representative in the EU/EEA to do the work.

Firstly you should be getting declarations from as many of your suppliers as possible as to the REACh status of the parts they sell you. From this you should be able to identify if there is any issue or not.

Generally for a lot of electronics the product is not affected by REACh or if it does include affected parts then you are below the threshold for weight. This typically means the only liability for you under REACh is to make a REACH article 33 declaration for the existence of an article or articles in in the product which are subject to the REACh restrictions. this declaration can be on your website (or a similar location) or supplied with the product.

Things however changed last Christmas with the introduction of SCIP. This now means that for every article you supply your EU/EEA representative must make a declaration on the SCIP database and show not only the product affected but all the sub assemblies and complex articles that might contain the affected article. Note under EU law (and the O5A definition) a brass pin in a trim pot which has lead in it to aid machining is an Article in its own right and will remain one for ever. So technically you have to declare the pin, the trim pot, the PCBA with the pot on it, possibly a sub assembly or two and the finished product. This is much more complex and awkward to do but there are several consultancies out there who can help. SCIP is technically under the waste framework not REACh but applies the same rules.

If you have not already looked into SCIP I suggest you do so a
 

SpinDr99

Involved In Discussions
#4
Thanks for your very helpful replies. Especially the guidance relative to the REACH article 33 declaration from Cynewulf. I do believe we are well below the weight threshold for reporting. We only sell electronic components and have no sub-assemblies. However, we have no idea what complex articles would have our components. SCIP seems to be a true Pandora's Box. I'll have to dig deeper and seek out a consultant, as this is far beyond my realm of knowledge. I'm open to referrals in the northeast U.S. (is a one-on-one message possible on the Cove?)
 
#5
There are a number of major players out there for supporting this. A good starting place is to look at the list of companies on the IPC-1752A Verified Solution Providers list on the IPC website as generally you need an FMD to properly understand the information required to upload to SCIP
 
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