As the REACH (Registration, Evaluation and Authorization of Chemicals) initiative moves toward law in the European Union (EU), the electronics industry will have to assess the law’s impact and make changes in products accordingly. So far, it’s difficult to tell just how many changes OEMs will have to make to comply with REACH.
For the most part, the electronics industry has not yet fully engaged in preparing for REACH. “OEMs are starting to become aware of REACH, but RoHS has so consumed people’s attention that there hasn’t been much time for most to see beyond it,” says Mark Myles, services director at the Goodbye Chain Groups, a firm in Concord, Ma. that helps companies develop environmental compliance strategies. “Some of our clients, however, realize that the same sort of effort required for RoHS compliance will apply to REACH as well as other environmental compliance legislation such as the EU packing directives and the many U.S. state substances bans such as the mercury restriction here in Massachusetts.”
Myles notes that the REACH directive will not have as much an impact on the electronics industries as it will have on OEMs in industries that use a larger portion of toxic chemicals in their products and manufacturing processes. “REACH’s impact will not be as great as it will be on other industries such as cosmetics and textiles,” says Myles.
As with the RoHS directive, there are copycat versions of REACH on the horizon in Asia and in individual North American states and provinces. “We know the Europeans are working with China on a law similar to REACH,” says Michael Kirschner, president of Design Chain Associates, a San Francisco company that consults on environmental compliance. “They’re trying to help China draft chemical policy. California is not quite at the point of saying yes to REACH-like laws, but the state senate has commissioned a study on chemical policy.” Kirschner notes the study was released in March and it recommends the state draft a chemical policy.
While Kirschner doesn’t necessarily expect California to propose legislation similar to REACH, he does note that REACH addresses many of the concerns in the California study’s chemical policy recommendations. California policy makers have also received input from the EU. “There was a California senate Environmental Quality Committee meeting in July to discuss and report and present its conclusions, and one of the co-authors of REACH was there to make comments,” says Kirschner.
One of the major concerns – around both RoHS and REACH – is that a plethora of laws in various nations, states and provinces will make compliance difficult if not impossible. OEMs certainly can’t build different products to comply with the requirements of individual geographical territories, so the preferred solution is to build a product that complies with laws in all territories. Yet, as dozens of nations, states and provinces develop individual law, universal compliance might not be possible.
One solution the electronics industry is hoping for is federal environmental laws that will supercede state law and give the industry one target to environmental compliance in the Unites States. “Here in North America, the greatest legislative activity seems to be at the state and provincial level, which is resulting in an enormous patchwork of sometime-conflicting laws,” says Myles of the Goodbye Chain Group. “This is prompting industry groups to lobby for federal legislation that permits uniformity across the country.”