Distributors Drive REACh Response

REACh – the European Union’s Registration, Evaluation, Authorization and Restriction of Chemical substances environmental reform legislation – is without question one of the most complex of all EU environmental regulations. It will require the establishment of comprehensive safety data and risk assessment on more than 30,000 substances that are deemed a high risk to environment, health and safety. The regulation has a Dec. 1, 2008 cut-off date looms for substances pre-registration. And, when IPC, the association connecting electronics industries, Bannockburn, Ill., revealed that at least 40 percent of North American manufacturers have little or no understanding of the REACh requirements, it came as little surprise to industry insiders.

Like its cousin RoHS (the 2006 regulation Restriction of Hazardous Substances), REACh is expected to have significant long-term impact on the electronics supply chain. Most notably – the tidal wave of end of life notices that are likely to flood the supply chain as component makers seek to reduce their environmental exposure by eliminating the use of certain chemicals, said Georg Steinberger, vice president communications, Avnet Electronics Marketing Europe, Middle East and Africa (EMEA). Steinberger also heads up Avnet Inc.’s Green Council.

Steinberger advises customers and suppliers to focus on establishing open communications channels early on with trading partners in an effort to minimize the possibility of supply chain disruptions. “The earlier information is provided and obligations are fulfilled, the better the stability of the supply chain can be ensured,” he noted. “Our central role in the supply chain gives us the unique capacity to facilitate transparent communication between OEMs and component makers. However, we cannot do it alone. All partners in the supply chain need to communicate early and openly, figure out their role and act accordingly.”

To help trading partners understand their role in the compliance process, Newark has created the Step-by-Step Guide to REACh, which has been adopted by the National Electronic Distributors Association as well as trade organizations in the United Kingdom and Germany as key training and awareness material, said Gary Nevison, director of legislation and environmental affairs for Chicago-based Newark, a part of the global Premier Farnell Group. Newark also maintains a Web site dedicated to legislation, including information on environmental regulations including RoHS and REACh.

Once REACh goes into effect, authorized distributors’ role will shift from creating awareness and facilitating communications to obsolescence management, said Steinberger. The European Chemicals Agency (ECHA) has estimated that the high cost of compliance is likely to drive at least 2 percent of the more than 30,000 classified chemicals listed with ECHA off the market. As a result, OEMs are going to need even greater assistance in incorporating more environmentally friendly products into their designs, said Michael Kirschner, president of Design Chain Associates, LLC, San Francisco.

Distributors’ diverse technical resources can help guide OEM design engineers to “design for the environment” by offering component options that don’t include non-registered chemicals or any of the substances of very high concern (SVHCs), said Steinberger. SVHCs are materials that are deemed carcinogenic, mutagenic or toxic. The ECHA will maintain a list of these materials which will not only need to be registered, but will require specific authorization for use. If ECHA determines that safer alternatives are available, authorization may not be granted. An initial list of 16 hazardous chemicals was released at the end of June 2008, but additional substances may be proposed as often as twice a year, reported Kirschner.

In addition to its team of field application engineers, Avnet also supports customers’ green design requirements through its “Promiere Green” fee-for-service solution, said Steinberger. Promiere Green provides compliance data, comprehensive certification, manufacturing and environmental component information, as well as custom solutions such as predicted end-of-life information, material declaration sheets and expedited-part data creation.

Since compliance with REACh will be an ongoing effort as new chemicals are added to the roster, OEMs that take a haphazard approach to compliance can expect to have difficulty competing against more proactive competitors that have products with better real or perceived environmental performance, noted Kirschner. On the other hand, he said, those that invest the time and resources to develop a coherent strategy for dealing with product-targeted environmental regulations like REACh will discover that their costs will decrease over time while their competitive advantage increases.

In the end, these efforts will not only create a more environmentally responsible supply chain, but a healthier world. The ECHA has estimated that once REACh has been established for 10 to 30 years, there will be approximately 4,500 fewer cancer-related deaths and 90,000 fewer cases of asthma, allergies and skin and eye disorders each year. “This is going to cost all industry tens of billions of euros…maybe hundreds,” said Kirschner. “But at least there will be a benefit to the environment from it.”