REGULATION & COMPLIANCE non-EU countries are not obliged to report SVHCs to the SCIP database . Data collection from suppliers within the EU may also be challenging , since almost every company is going through the same process of trying to collect data from their suppliers and manufacturers of articles , who are likely to be based in both the EU and outside of it .
No obligation = no data ?
As mentioned above , companies from many countries outside of the EU and EEA are not bound by obligations to communicate SVHCs in articles . Therefore , they do not actively communicate these data . The reasons for this are twofold :
• Some entities do not even know this obligation exists , what SVHCs or candidate lists are , and why this information is so important
• There may be a very long supply chain , where the process of going through or scanning it and collecting information about the manufacturer is very time-consuming Once a company imports parts from non-EU countries , it becomes the first in the supply chain with the duty to comply with REACH and the WFD . At that point , the challenge to motivate non-EU suppliers to share information on SVHCs in supplied parts arises . In our experience , the best solution here is to actively communicate with your non-EU suppliers and educate and introduce them to the advantages of sharing information .
It indeed takes a lot of time and effort , but the result of being compliant and participating in creating a safer environment without chemicals of concern is , with utter certainty , worth it . We do our best to provide the suppliers with the most up-to-date and valid information , making it easy to understand even for a person who does not have a chemical or legislative background .
Top tips
Here are some tips on how to explain to a non-EU supplier why there is a request to evaluate , collect and share information on SVHC substances when a supplier is not concerned by this legal duty .
Firstly , prepare the supplier for upcoming requests . Let them know , you are going to inquire about the substances contained in parts , even if the data is requested retrospectively after purchasing . Educate the suppliers . Information leaflets or a short presentation have both proven successful .
Regartis has experience in launching webinars adapted for supplier representatives without a chemical or legal background , which is beneficial , especially for small suppliers , where there is no specialist with a background to know the reason for the request and skills to deal with it . This kind of communication helps to raise awareness of SVHCs and can help build better relationships with suppliers .
Along our professional journey , we meet inspiring examples of companies based outside of the EU , actively testing their parts or materials and providing analytic reports to their customers in the EU or the information upon request .
We believe that properly built communication with suppliers can make the whole supply chain and data collection process considerably more efficient and productive .
Some non-EU companies that are not bound by EU obligations may have to comply with similar regulations and requirements in their country . For example , the UK , where , after Brexit , companies do not have the SCIP database reporting obligation .
However , the information on SVHC content and presence in articles still must be communicated according to the adopted UK REACH regulation within the supply chain and must be reported to the Health & Safety Executive ( HSE ) using the current IUCLID format . When such compliance requirements are already in force , there comes an opportunity for non-EU suppliers to facilitate data collection , both to ensure their compliance locally and for future opportunities .
What should you do if you have tried everything but received no data from your non-EU supplier ? Conducting a chemical analysis may be an option to obtain information on the composition
MAY / JUN 2024 SPECCHEMONLINE . COM
51