Effect of REACH on SME’S
Posted Under: REACH Compliance Services REACH Consulting Services REACH is world’s strictest chemical law, for any business in European Union either large or small.From the starting itself, one of the main concern was how SME’s (Small and medium enterprises) could adapt to the Regulation. After all, almost 27,600 companies in EU market are SMEs (95% of all firms). Already seven years are over after the implementation many of these fears are still hanging around. Assuming no significant changes are introduced to REACH. SMEs importance in European Union (EU) 99% of all companies in the EU are SMEM 23 million SMEs employ 75 million people SME create one in every two new jobs SME are responsible for more than 50% of the total value-added created by businesses in the UK SMEs pay 80% of EU taxes and are therefore essential components of growth of Europe This means that the EU growth strategy depends upon a stable and healthy business environment for SMEs Around 25,000 REACH registrations have already been submitted. By the 31 May 2013, 3,215 companies submitted 9,084 registration dossiers to ECHA. Since the start of REACH in 2008, a total of 6,598 substances have been registered. For the 2010 and 2013 REACH registration deadlines, the amount of dossiers submitted by SMEs amounted to 14% and 20%, respectively About REACH The strictness of the regulation can only be justified, if the benefits are impressive and outplay the costs by a large margin. But ECHA is speaking about health and environmental benefits, And the increase in job opportunities which is not convincing SME’s than its problems. The 2013 REACH Review also tells about benefits which will be effective in only ten to twenty years and acknowledges that the benefits for SME’s do not seem to compensate the costs for the process to get compliant. In general, it is expected that larger companies will have more options and ways available to comply with regulatory demands in comparison to small ones. Cost and administrative problems of REACH for SME Now the REACH has taken its Role on SMEs, which is of serious concern because SMEs are the backbone of the economy, and it is important to have the right balancing conditions to get the economy moving again by helping SMEs. The 2013-2018 deadline means that REACH is highly going to affect on SME now.. Submitting quality dossiers is a significant resource cost for SME The main problem is related to an uneven share of the costs. SMEs will be having more disadvantage compared to bigger or very large companies, particularly as they are dealing with lower volumes of chemicals than bigger firms. This results in higher costs per unit. Most SMEs use consultants for registration activities. It is estimated that the costs of consultants correspond to some 10 % of registration costs, at times more like 10% – 25%. Even though 82% of the pre-registering companies were SMEs , yet only a few of these have actually completed the registration process up to now. In addition, dealing with more substances also implicates that more efforts are necessary to communicate information along the supply chain. As a result, REACH seems to lead to a competitive disadvantage for SMEs, due to costs, training, 1resources required, as well as other factors including uncertainty in the case of some substances. Major sources of costs relate to testing, consultants and other forms of support to navigate through REACH complexity, but costs related to restructuring of existing plants in order to comply with stricter requirements for containment systems may be necessary, too. In addition, the time r enquired to become and remain compliant e.g. fulfil processes like volume tracking, submission/maintenance of registrations, preparation of SDSs (safety data sheets) with exposure scenarios and communication up and down the supply chain is expensive and may draw attention and resources away from other business processes It is to be noted that the financial situation of companies is made more difficult due to REACH, the overall direct costs are much higher than initially published: some 1.1 billion (in euros of 2011) in 2003 as against some 2.1 billion today. The new and more robust estimate, based on empirical evidence this time, is nearly double the amount in the 2003 Commission Impact Assessment. And in absolute terms no less than 1 billion this difference it is sizeable, too. The costs of access to data in a SIEF (for data sharing in case of joint registration, based on so-called Letters-of-Access [LoA] ) were not foreseen In general due to lower volumes, unit costs are higher for SMEs in SIEF’s than for large companies, and when they add up i.e. if there are many substances the cost Competitiveness of SMEs becomes a serious problem. Moreover, additional expenses will have to be incurred when updates of the dossier are needed. Is the diversion of R&D resources to REACH-compliance, which hampers innovation. Besides for direct work on compliance, resources from R&D are also increasingly used for investigations on substitution of raw materials, either by replacing non-REACH compliant suppliers with REACH compliant suppliers. Extended Safety Data Sheets (eSDS) often requires complex interactions and information Exchange within the supply chain, triggering the need for IT tools to manage these streams Adequately and provide insight in the? ill of materials These tools are available in the Market, but are expensive and need to be tailor made for the company. SMEs often have less overview of their tasks and may look for cheap solutions that in the end meet only a part of their specific needs The administrative burden of supply chain communication is large, as all communications and decisions need to be documented and may need to be made available to the authorities to prove compliance Regarding IT tools like REACH IT, IUCLID, CHESAR, and the frequent updates of these tools from the ECHA side (the latter was often cited as a major source of frustration, because what seems like a minor IT change in Helsinki sometimes requires re-entering a
Hazardous Substances In Electrical And Electronic Toys
Posted Under: RoHS Compliance Services RoHS Consulting Services It is important that the significance of Children’s play toys are recognized as modern European societies face various economic, social and environmental challenges. Children’s play toys have a vital role in this modern world. To improve the intellectual and physical growth in children toys are essential. We can even say that toys are the intimate friends of children. Many countries have implemented rigorous safety measures on toys as most of the children who play with these toys are under the age of 5. Compared to adults, children are more sensitive to chemicals and their bodies should never be exposed to hazardous chemicals or materials. Chemicals are used in toys mainly to make them softer. There are certain chemicals that have been identified as hazardous and they are strictly prohibited from use during the manufacturing processes for toys. Therefore there are regulations created to control and forbid the use of hazardous chemical substances in toys. In July 1989, the British government adopted the EEC toy safety directive ( 88/378/EEC) and this regulation came in to effect on the 1st of January 1990.This directive ensures that there is free circulation of toys and all these toys are required to have a CE marking along with the name and the address of the first supplier. In 2012, a final report was prepared for the European Commission, which revealed that some of the member states had argued stating toys, irrespective of whether their primary function uses electrical energy, they are under the scope of RoHS as these toys are under the category 7 of the WEEE Directive. These Member States are known to have considered all toys that use electrical energy to fall under the scope of RoHS. For MS national legislation all EE toys, including the secondary function toys have been under the scope of RoHS and consequently the expectation is that the national requirement may be that all EE toys must be RoHS 2 compliant by January 2013. The original toy directive that is 88/378/EEC was published in 1988. The EC (European Commission) reviews and updates this directive periodically to ensure that it achieves its objectives. Recent technological developments in the toy industry have raised new issues with regard to the safety of toys in areas such as noise, chemicals, and choking hazards. As a result, a newer EU Toy Safety Directive named 2009/48/EC was introduced to strengthen and update the rules on toy safety. This directive (2009/48/EC) was adopted on May 11 2009 by the European commission and this came into effect on the 20th of July 2011. Benefits of RoHS EU Toy Safety Directive RoHS, an environmental directive, is independent from the EU Toy Safety Directive (2009/48/EC) and may be it would apply to all Electrical and Electronic Equipment, but EE toys are definitely included. In its recast, which is known as RoHS 2, the scope extends from toys with a primary electrical function (RoHS, Category 7) to all EE toys, including those whose electrical function is only secondary to the overall play value. For example, a cuddly toy that talks – its primary function as a cuddly toy was exempt by a guidance document from RoHS 1, but now it will fall under the scope of RoHS 2 because it is electrically powered to fulfill this intended function. Nitrosamines and nitrosatable substances shall be prohibited from use in toys that are intended to be used by children who are under the age of 36 months, or in other toys that are meant to be placed in the mouth if the migration of these substances are equal to or higher than 0.05 mg/kg and 1 mg/kg for nitrosamines and nitrosatable substances respectively. Although the overall level of compliance to RoHS in the EU is high, some of the product categories are problematic. According to all enforcement reports, the biggest problem is the presence of lead in imported electrical toys. In proportion to the Commission’s knowledge, the member states will control those activities that are focused on sold equipment and not on components, as the RoHS restrictions apply to the finished product. The Toy Industry Association supports and facilitates trade between the United States and the European Union. Mutual recognition could address most of the divergences in regulations that would burden companies who sell to both the markets while reinforcing consumer confidence that toys compliant with either standard can be trusted as safe for children. Moreover, establishing a strong regulatory cooperation agreement will ensure a joint U.S. – EU leadership in international regulations.This provides a basis for future trade agreements and also helps to provide a benchmark for the development of other standards pertaining to other countries.
Conflict Minerals Compliance – The Deadline Is Approaching
May 31, 2014 is a key date for all public companies listed with the SEC, as the first Conflict Minerals Report has to be filed by this day. The Conflict Minerals Rule enacted by the SEC,as part of the Dodd-Frank Wall Street Reform and Consumer Protection Act, requires certain public companies to provide disclosures on the use of conflict minerals in their products and whether they originated at mines run by warlords in the Democratic Republic of the Congo (DRC) or its nine adjoining neighbors. Compliance is mandatory for all SEC “issuers”, including foreign issuers, that manufacture or contract to manufacture products where “conflict minerals are necessary to the functionality or production” of the product. The rule was enacted as part of an effort to curtail human rights abuses in Africa by regulation of US public companies and also to provide transparency into corporate practices. The SEC rule does not specifically ban use of materials from such mines, but it requires companies to track and report the origin of the minerals through their supply chain. The aim is to dissuade companies from using minerals sourced at mines where human rights abuses take place and not engaging in trade that facilitates regional conflict. The SEC disclosure process involves the following steps Minerals that are not conflict free must be listed in the Conflict Minerals Report, which must be audited by an independent auditor. Additional documentation is also required for any materials that come from the affected countries to show that it meets the Organisation for Economic Co-operation and Development (OECD) due-diligence procedures documenting and the materials are conflict free. The first Forms under the rule will be required for the calendar year ending December 31, 2013 and will need to be filed by 31 May 2014. For most companies compliance with the Conflict Minerals Rule will not be easy and will be time consuming with the SEC estimating that initial compliance costs could be between $3 billion to $4 billion,as the complete supply chain needs to be analyzed for source of minerals, particularly those contained in procured parts, assemblies or items purchased from vendors. The fact that the supply base is not geared to address these requirements and the information provided by them is not always accurate only adds to the challenge. Hence, it requires multidisciplinary teams working across product lines and tracing multiple supply chains for these materials and their origin. On one hand, committing to using only conflict-free materials can mean paying higher costs for those materials but on the other hand a company’s reputation and goodwill is at risk if its products include conflict minerals. Despite the challenges and oppositions raised against various sections of the rule in court, experts believe that ultimately compliance will be mandatory and in fact will be extended to include more industries currently exempt from the rule. Therefore, a company that is committed to a conflict-free business plan can leverage its status towards strategic competitive advantage and be seen as a good corporate citizen. Enventure is an industry leader in the compliance space and is one of the first companies to offer engineering services that will help you comply with this regulation.
EU RoHS 2 Compliance-Some of the important details that you must know
ROHS, the Directive to limit or rather ban the usage of dangerous substances in electrical and electronic equipments manufacturing, was put-forth by the European Union in February 2003. Five years after the launch of RoHS 1, EU has now adopted the new RoHS Directive or RoHS 2, with more rigid rules to put an end to the usage of toxic substances in electrical & electronic products manufacturing industry. However, there are a lot of companies and factories out there, who are not aware of the new RoHS 2 Directive. According to environmental compliance experts, RoHS 2 Directive will soon create a major impact on electronic industry, and electronic products manufacturing companies. RoHS 2 Directive was initially published in the Official Journal of EU, on July 1st, 2011, and entered in to force on July 21st 2011. According to EU & environmental compliance experts out there, RoHS 2 Directive will replace RoHS 1 on January 3rd, 2013. Hence electronic products manufacturing companies should have a comprehensive idea about the new RoHS Directive rules and regulations RoHS 2 covers a wide range of products including small & large household appliances, IT & telecommunication, consumer equipments, lighting equipments, electric and electronic tools, and medical devices. But RoHS 2 doesn’t apply to certain products like military equipments, space equipments, equipments which are designed and manufactured to form the part of equipments which are not within the scope, large scale industry tools, large scale fixed installations, various means of transport, non-road mobile machines, active implantable medical devices, and photovoltaic panels. Therefore electronic products manufacturing companies should have a very clear idea about product categories of EU RoHS. RoHS 1 was brought into force to curb or rather completely ban the usage of 6 major hazardous materials – lead, mercury, cadmium, hexavalent chromium, polybrominated biphenyl, and polybrominated diphenyl ethers. According to the reports of EU, these chemicals are highly toxic to humans and extremely harmful to the environment too. RoHS 2 also restricts the usage of all the above mentioned chemicals, with the help of more rigid rules and regulations. Electrical and electronic products companies in the EU are legally bound to obey the rules of EUL legislation. This also applies to the companies that export electrical and electronic products to any of the countries in the EU. Unawareness of these rules will never be considered as a viable excuse, and therefore it is very important to learn about RoHS , to ensure that your products are fully RoHS compliant. To know about the rules and regulations of EU, companies can contact environmental compliance experts like Enventure Technology Services. We help companies comply to RoHS and its different country flavours, by providing them with a comprehensive audit report about their products, and the materials that they use in the Bills of Materials during product manufacturing. Our experts will also provide environmental compliance consulting services, bill of material assessment, product conversion, and other required solutions to help companies understand and comply with the EU directives. Need any guidance on environmental compliance & RoHS Directive? Drop us a line and we will get back to you as soon as possible!
Must-Know Facts You Probably Don’t Know About Conflict Minerals
It’s been almost a century since Democratic Republic of Congo has been consistently exploited for its vast natural resources & mineral wealth. According to the reports submitted before the Congolese Parliament, a few years back, the investigation committee had uncovered some really shocking details about the ongoing illegal exploitation of Congo‘s natural resources, and the illegal trade of Congo’s Conflict Minerals. Conflict Minerals are mined in conditions of ‘armed conflicts and human rights abuses’. Minerals including casseterite, wolframite, coltan, and gold are widely extracted from Congo, especially from its eastern parts. These minerals are purchased by various multinational electronic companies across the world, and are widely used to manufacture of a variety of electronic devices including mobile phones, laptops, MP3 players, and various other consumer electronic items. Conflict Minerals Regulation Act aims to put an end to the constant exploitation and atrocities going on in Congo, by closely monitoring the issuers & the companies that use Conflict Minerals. According to this act, both domestic and foreign providers of Conflict Minerals, as well as the companies that use them, are forcefully obliged to comply with Section 1502 of the Dodd-Frank Wall Street Reform and Consumer Protection Act (Conflicts Minerals Provision), and therefore should disclose the details of the Conflict Minerals that they use, in their annual reports. This public disclosure will highlight the exploitation and trade of minerals from Democratic Republic of Congo and its adjoining countries. Dodd–Frank Wall Street Reform and Consumer Protection Act was passed by the US Senate on May 20, 2010, and was signed by American President Barack Obama on July 21, 2010. According to experts, this Act will completely purge the funding of armed groups in Democratic Republic of Congo. Armed groups in and around Congo make millions of dollars every year by selling Conflict Minerals and their derivatives, to various companies across the world. According to the Conflict Minerals Regulation Act, companies are legally bound to publically disclose whether their products contain conflict minerals or not, while submitting their annual reports. Companies that use Conflict Minerals should file a separate report along with their annual report, stating the steps taken to properly exercise the due diligence on the source and the chain of custody of the conflict minerals, the details of the products which are not “DRC Conflict Free”, the processing facilities, the country of origin of the Conflict Minerals, and the efforts to determine the origin. Such reports would help in getting better transparency and accountability from those companies & issuers who handle Conflict Mineral ores or their derivatives. Enventure Technologies, global leaders in environmental compliance services, provide Conflict Minerals traceability auditing & consulting services to help companies and businesses understand and comply with the Conflict Minerals Regulation requirements that may impact the manufacture of their products. We have a team of environmental compliance experts who can address your questions regarding Conflict Minerals Disclosure, and provide you with the needed guidance with the compliance requirements of Securities and Exchange Commission. Need any guidance on environmental compliance & Conflict Minerals Disclosure? Drop us a line and we will get back to you as soon as possible!