If the RoHS sweep does not scare you as a company, just wait for the REACH sweeps and SVHC list.
RoHS is the tip of the iceberg and paved the way for the much larger REACH program that will cost companies billions, put at risk companies IP.
REACH is being marketed at a greener way to test for substances and the goal is to combine all substances into one massive database so that we can "Share" in the knowledge of how substances effect our environment. However as this is generated so to is the SVHC (Substances of Very High Concern) that list those substances that the EU feels is not in the best interest of the environment (or better way to state it is the list that EU can apply a substance Tariff that will allow for the continued import.) Also a good way to get information on companies IP.
So be ready to have your checkbook ready, as it is free this year to register what it is you ship into the EU and at what tonnage you ship it. You can bet there will be a yearly bill sent to you and your company for the importing of that substance.
It is hard to not be sympathetic to Peg's concerns, where RoHS is only six pages and controls only 6 substances, REACH is over 800 pages and some suggest will cover up to 30,000 compounds. Here are some key REACH points:
- Its focus is for companies that export chemicals/materials to the EU, as opposed to electronics products.
- Companys that export more than 1 ton of materail to the EU need to pre-register the materials now. The deadline is November 30th.
- You will then be assgned to participate in Substance Information Exchange Forum (SIEF) in which you will exchange information with others and perhaps perfrom experiments to demonstrate the safety of a substance.
- Substances of Very High Concern (SVHC) will get the immediated attendion of the EU.
- If your vendors supply you with a chemical that you incorporate into one of your materials, they must pre-register their chemical, to assure that you can use it.
- Becasue of the mandated participation in SIEFs IP may be at risk.
All in all Yikes!