REACH and RoHS ensure that hazardous substances in products and packaging are restricted and controlled. Companies that are compliant not only meet legislation but also strengthen their reliability in the chain and reduce their environmental impact.
Summary of this article
REACH and RoHS: more and more manufacturers, retailers and suppliers are having to deal with them. They are being asked to issue a REACH or RoHS declaration. But why really? What do these standards mean? And why are they so important?
RoHS II, which stands for Restriction of Hazardous Substances, restricts the use of certain hazardous substances in the manufacture of electrical and electronic equipment. These include mercury, lead, cadmium, hexavalent chromium, PBBs and PBDEs. The latter two are substances used for their flame-retardant properties in plastics. RoHS is intended to protect human health and the environment.
REACH stands for Registration, Evaluation, Authorisation and Restriction of Chemicals. REACH is a European regulation that, like RoHS, aims to improve the protection of human health and the environment from the risks posed by chemical substances.
The rules governing the use of hazardous substances and chemicals are becoming increasingly strict. In the EU, it is illegal to sell or import electrical and electronic equipment that does not comply with the requirements of the RoHS Directive.
Responsible manufacturing has become the norm. Being unable to demonstrate compliance with REACH and RoHS can affect cooperation throughout the supply chain. As a result, more and more suppliers are being audited by major customers to verify whether they are genuinely REACH and RoHS compliant.
For electrical and electronic equipment that falls within the scope of the RoHS Directive, the manufacturer is responsible for ensuring that the product complies with the applicable requirements. The manufacturer must be able to demonstrate that restricted hazardous substances do not exceed the permitted concentration limits, unless a specific exemption applies.
Formally, this is supported by technical documentation, an EU Declaration of Conformity and the CE marking on the finished product. In practice, customers often also request a separate RoHS declaration from their suppliers. In this declaration, the supplier confirms that a product, material or component complies with the applicable RoHS requirements.
REACH does not prescribe a single general declaration or standard certificate. The obligations that apply depend on a company’s role in the supply chain and on the substances, mixtures or products it manufactures, uses, imports or supplies.
In practice, a so-called REACH declaration is usually a supplier declaration. It may, for example, state that a product complies with the restrictions imposed under REACH and whether it contains any Substances of Very High Concern included on the European Candidate List.
REACH may impose obligations on companies that:
Companies that do not consider themselves part of the chemical industry may therefore still be affected by REACH. Examples include businesses that work with adhesives, coatings, metals, cleaning products or plastics.
A company must first determine its role under REACH. It must then identify the substances, mixtures and materials it uses, imports or supplies. This includes collecting and assessing safety data sheets and relevant information provided by suppliers.
Additional obligations may apply depending on the situation. Manufacturers and importers, for example, must register certain substances. Professional users must check whether their intended use and operating conditions are covered by the safety information they receive.
Information and notification obligations may also apply to products containing a substance included on the Candidate List. If the concentration exceeds 0.1% by weight, the supplier must provide its business customers with sufficient information to enable the product to be used safely.
If a product does not meet the applicable REACH or RoHS requirements, its use or placement on the market may be restricted or prohibited. Depending on the nature of the violation and the relevant national enforcement measures, a company may also be required to withdraw or recall products.
Non-compliance can also affect cooperation throughout the supply chain. Customers rely on information from their suppliers to assess their own products and processes. If you are unable to provide the required evidence, this may lead to delays, additional investigations or the customer choosing another supplier.
At Faes, we incorporate REACH and RoHS requirements into our agreements with suppliers. We ask them to provide relevant declarations and supporting information. This gives us greater insight into the materials and components we use and enables us to respond carefully and accurately to questions from our customers.
A declaration alone is not always sufficient. The information must relate to the specific product and materials concerned and must reflect current legislation and regulations. We therefore continue to review the available documentation and our agreements throughout the supply chain.
In addition to our focus on REACH and RoHS, Faes is now ISO 14001 certified. Through our environmental management system, we systematically identify the environmental aspects and risks associated with our operations. We document how these are managed, monitor our performance and work towards continual improvement.
This means that our environmental policy is not merely an ambition, but an integral part of our day-to-day processes and decision-making. ISO 14001 certification confirms that our environmental management system has been assessed by an independent certification body.
Would you like to know which requirements apply to your product, packaging or supply chain? Our packaging experts can help you identify the relevant regulations and the documentation you need. Contact us directly or find more information in our knowledge centre.
Robert Verboven is Sales Manager at Faes and advises customers on smart packaging solutions within the industry. He translates complex packaging needs into practical solutions that contribute to a more efficient supply chain.
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