REACH SVHC Candidate list updated
European Chemical Agency, ECHA has updated the candidate list of substance of very high concern for authorisation, in accordance with Article 59(10) of REACH regulation Annex XIV. On 25th June 2020, below 4 new chemicals added to SVHC list, making it from 205 to 209. 1-vinylimidazoleCAS: 1072-63-5Reason: Toxic for reproduction as per Article 57 (c).Found in: Production of polymers, antifoaming agents, coagulating agents, surface treatment of metals 2-methylimidazoleCAS: 693-98-1Reason: Toxic for reproduction as per Article 57 (c).Found in: Paints, varnishes, plastics as hardening promoter, manufacturing, casting and surface treatments of metals, plastic products. Dibutylbis(pentane-2,4-dionato-O,O’)tinCAS: 22673-19-4Reason: Toxic for reproduction as per Article 57 (c).Found in: As an additive and catalyst in plastic production, paints, sealants. Butyl 4-hydroxybenzoate (Butylparaben)CAS: 94-26-8Reason: Endocrine disrupting properties – human health as per Article 57(f) – human health.Found in: Cosmetics, personal care products and pharmaceuticals, flavouring agent Do you want to know, whether you company and products come under the purview of EU REACH Regulations? Talk to one of REACH Compliance Specialists today!
All you need to know about Conflict Minerals
We regularly use various products most possibly containing so-called conflict minerals—rare natural resources such as tantalum, tin, tungsten and gold (3TG), the mining and trade of which results in financial conflicts and human abuse in the Democratic Republic of Congo (DRC) and the adjoining countries. What is covered in this blog to help manufacturers and suppliers? The challenges in conflict minerals reporting program. Why conflict Minerals training is important for your business and your suppliers. How important it is to file under SEC/ to follow/ comply with CM regulation. What does the Dodd-Frank Wall Street Reform Act do? Dodd-Frank 1502 was the first Financial Reform Legislation signed by Former President Barack Obama in 2010 to distinguish between conflict and conflict-free mines. The main goal of the rule is to choke off funding for warlords and militants committing atrocities to run the mines using forced labor and abusive actions. As many companies think, the law does not require companies to stop sourcing 3TG from DRC and also does not force to source from conflict-free mines. The law only requires companies to file under SEC to report on the RCOI (mineral sourcing) and due diligence process. It creates transparency among companies which will help to sell or buy products with assured satisfaction to the suppliers and customers. This will enhance a company’s reputation as a good corporate member by avoiding the purchase of raw minerals from conflict mines and also supporting the law against human abuse. The law is still on its path to reduce the trade of armed militants by significantly reducing the price of conflict-free 3TGs than the price of conflict-3TGs. The high cost and lack of demand created a two-tier market with positive approach for conflict-free mines. This reduces the number of conflict mines in DRC regions. Approximately more than 75% companies and suppliers accepted the justice behind the law and started to follow the guidelines provided by SEC. Supplier’s interest on conducting RCOI, due diligence process and third-party audits is increasing day by day. These actions will improve the Business strategies, Compliance status, Supply chain management and financial performance of a company in the wide and wild corporate world. How to become conflict-free? A Company needs to form cross-functional teams to efficiently track the source of minerals through supply chain management. It is very important to decide whether to blindly comply with the requirements of the law or to perfectly agree and try to work towards the goal. As we think this is not an easy task to withstand ones Companys’ reputation and goodwill among the Competitors, no matter what, they have to stand against conflict mines and ensure that their tier suppliers also supply conflict-free minerals. It is really good to sign a Compliance agreement with the tier suppliers, distributors, smelters or refiners to prohibit the use of conflict minerals. Once the strategy is set, it is the management’s responsibility to accomplish the task efficiently. Do you have a question that whether your company is subject to SEC rule? According to the legislation, the law applies only to publicly traded companies of SEC jurisdiction in U.S. However, it is necessary to comply with the law even if your company does not fall under SEC rule, as your suppliers or distributors may comply with the law. Similarly, your tier suppliers down the globe may require companies including private sectors to remain conflict-free to lead a good business relationship. So, the law gives an international impact, affecting countless number of companies worldwide. Compliance Challenges: The first and foremost challenge would be the cost to track down the entire supply chain. The more complex a product, the more complex would be to trace the origin of the minerals used in the product. Aligning thousands of suppliers on a single chain is a huge and costly challenge. After all that, the process is time consuming and error-prone. Thus, compliance documentation becomes impractical for many companies. Apart from challenges faced by the companies on cost and supplier tracking, Compliance activities play a high priority role in most of the industries. Compliance Strategies: Affected companies are under pressure to take action and develop a strategy to comply with the law. Few steps to lead the compliance path- Determine whether your company complies with the SEC law. Understand the legislation established and how it affects your company. Form efficient team to handle the supply chain activities. Conduct a RCOI process to confirm the origin of the minerals used in the products. The RCOI can be processed through EICC and GeSI’s framework. If your products are sourced from DRC regions, then go for due diligence process and third-party audits. The framework developed by OECD is the only available guidance for due diligence process. Initiate trainings and seminars to make the suppliers understand the importance of the Act. Make sure your requirements are clearly explained. This include the Companies responsibility to build a good compliance chain. Review the data gathered from the entire supply chain and take necessary actions. Request your suppliers to remain conflict-free. Prepare a detailed Conflict minerals policy to share with your tier suppliers. File the Conflict Minerals Report (CMR) annually. Eliminate the contact with conflict suppliers for the next reporting as that will help to grow your business relationship with other suppliers and moreover remember that the competitors are gradually increasing in compliance field. These steps are similar to climbing a mountain. Fortunately, there are numerous data services companies to reduce your company’s burden and support them in Compliance. This will enable your company to face and overcome the challenge of managing, collecting and reporting conflict minerals information with less time and human effort. Finally, the most important target to meet, customer’s requirement and satisfaction, will be accomplished. Our compliance services focus on training, capacity-building and delivering strategy that allows companies to create efficiencies of their supply chain compliance. Talk to our compliance experts to learn more about being compliant to conflict mineral regulation and mitigate supply chain risks.
IMDS Compliance in Automotive Supply Chain & Recommendation 019
The International Material Data System (IMDS) is an online platform used by the automotive companies in order to manage their data on materials and substances of automobile parts.The IMDS Steering Committee has published several recommendations to define materials for creating Material Data Sheets (MDS) whereas in each recommendation, the guidelines for MDSs in different material categories have been defined. IMDS Recommendations give instructions on how to report the presence of declarable substances in parts and materials. In that IMDS Recommendation 019 is for Electric/Electronic components. This recommendation was first approved and released on October 30th, 2003. The current Rec 019 process was developed in 2013 in order to address the expanding requirements of the End of Life Vehicle Directive (2000/53/EC) and the communication requirements of REACH. Rec 019 describes the general requirements for the creation of Material Data Sheets (MDSs) applicable for Electric/Electronic components, materials at all levels of the supply chain, assembled printed circuit boards (PCB/PWB, including flexible circuit boards (FCP)) and hybrid electronics used in automotive applications. REC 019 provides supplier a modular approach to report materials in electronics components, including components containing lead, rather than reporting a fully exploded BOM. To facilitate the material data reporting process, several standard modules have been developed by IMDS Steering Committee. It not only involves the creation of standardized datasheets but also made a process that suppliers must go through to ensure that the information provided by them is in full compliance with legal requirements in the IMDS database. Recent decision of IMDS Recommendation 019 (REC 019) deactivation, removes the use of standard datasheet for electronic component and the reporting in IMDS. The decision made by the Steering Committee to deactivate this recommendation is concerted and it is mainly taken with the unacceptable risk because of the lack of supplier’s due diligence during the reporting process. As per the latest news from IMDS, the deactivation of REC 019 was postponed until the release 13 of IMDS, which is planned on Q1, 2021. Changes of Rec 019 in IMDS Reporting: As a result of REC 019 deactivation, it creates a big challenge to the supplier of automotive and electronic sector. It will also result in additional and differing customer-specific requests that companies must meet.Deactivation of REC 019 causes the electronics suppliers to collect Full Material Declarations (FMDs), real & accurate data from their supply chains to support the reporting and compliance needs of the automotive sector and manually enter this data into the IMDS. Based on the recent update of IMDS, all legally required substances contained in the supplied parts must be reported and the application code for the end of list vehicle must be declared. The REC 019 advises companies to ensure electronics suppliers begin performing internal reviews of material data and to ensure that the ELV heavy metal applications and REACH SVHCs, were accurately communicated in the IMDS database. If you are an automotive parts supplier IMDS compliance is an unavoidable. Our experts at ComplianceXL will help you by providing IMDS training to all supply chain stakeholders, and offload the tedious and time-consuming reporting task in IMDS management. If you are facing an IMDS deadline, our IMDS Data team will be able to bail you out. Talk to our IMDS specialists today!
Perfluorooctanoic acid (PFOA)- Restrictions and deadline
Per-and polyfluoroalkyl substances (PFAS) are a large family of synthetic chemicals widely used in the society. PFOA is one of those families present in PFAS. Since they contain Carbon chain of different lengths and the Hydrogen atoms are completely or partly substituted by Fluorine atoms, they form a very stable bond and are not degradable in the environment. PFOA can be found in Non-stick pans, furniture, cosmetics, household cleaners, clothings, packaged food containers, furniture treatments products, food wraps, sprays for leather, shoes and paints. EU has taken a regulatory approach to reduce the usage of PFOA and its salts under Annex I to Regulation (EU) 2019/1021.PFOA is considered as a substance of concern because of 2 main reasons. Toxic for reproduction Persistent, Bioaccumulative and Toxic Substance Perfluorooctanoic acid has CAS number 335-67-1.PFOA salts and polymers comes with formula C7F15- , C8F17- .Below are the substances that are excluded from this designation:— C8F17-X, where X is F, Cl, Br. — C8F17-CF2-X′ or C8F17-C(=O) OH, C8F17-C(=O )O-X′ (where X′ is any group, including salts). Important dates: 4 July 2020 PFOA should not be used in equal to or more than 25ppb including its salts or 1000ppb of one or a combination of PFOA related substance in any substance/constituent, mixture or article. 4 July 2022 This rule will apply to the equipment used to manufacture semi-conductors and latex printing inks. 4 July 2023 The rule will apply to textiles for the protection of workers, and membranes intended for use in medical textiles, filtration in water treatment, production processes and effluent treatment, and plasma nano-coatings. 4 July 2032 The rule applies to medical devices other than implantable medical devices within the scope of Directive 93/42/EEC. The US Environmental Protection Agency also regulates PFOA. On Feb 20,2020, EPA proposed regulatory determinations for perfluorooctanesulfonic acid (PFOS) and perfluorooctanoic acid (PFOA) in drinking water. On March 10 2020, EPA issued initial regulatory determination under the safe drinking water act (SDWA) for PFOS and PFOA. They also started 60 -day public comment box which expired on May 11,2020. The public comment period is for interested parties to submit the input to EPA regarding on adverse health effect of substance, frequency of presence of this substance in water and health risk. A negative finding will lead to withdrawing preliminary determination. Our REACH compliance experts keep a tab on developments on REACH regulation and help organisations meet their compliance requirements. Our expertise combined with consultancy services and experience in consumer product supply chain provides an edge in understanding the specific requirement in such cases. Would you like to learn more about how ComplianceXL can support your REACH compliance activities? Talk to our compliance specialists today!