Design Con 2015

REACH Is Not Overreaching

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Mr. Roques
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Re: Common Sense
Mr. Roques   3/30/2012 4:38:38 PM
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Well, while it certainly adds "overhead", when done correctly, regulation is helping the industry in the long run. If left to the private sector, it probably ends up hurting the customers.

Michael Kirschner
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Re: Common Sense
Michael Kirschner   3/2/2012 5:13:45 PM
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Thank you for the question, Hawk. China, Korea, and Japan (at least) have introduced regulations that are (correctly or erroneously) referred to as "REACH-like" but as far as I can tell so far they only have impact for manufacturers of chemical substances and mixtures. Since we focus only on Articles I can't tell you how those provisions differ from EU REACH requirements. If, however, you review the Safer Chemicals bills introduced in the US House and Senate earlier in 2011 you will recognize some REACH-like provisions. But that't not law at this point.

Hawk
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Re: Common Sense
Hawk   2/29/2012 8:26:53 PM
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Michael, I believe Design Chain Associates has also in the past done reports on similar versions of REACH that are being introduced in other countries. If I am correct, China has its own version too. How different are these from the EU's program and how more difficult is it for companies to achieve compliance?

Michael Kirschner
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re:
Michael Kirschner   2/27/2012 12:16:32 PM
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jbond, thanks for the info. Neither of those are in the REACH candidate SVHC list (located here: http://bit.ly/svhc_list ) so he may be looking at another list which may or may not be related to REACH. Bottom line is that manufacturers are going to have to look at these properties before formulation, not afterwards. They're product design properties now.

Michael Kirschner
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Re: Common Sense
Michael Kirschner   2/27/2012 12:07:57 PM
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Bolaji, great questions. There has not been a study of cost of REACH compliance (as I said before , we did assess cost of RoHS compliance). So far, for the majority of the electronics industry the cost has been incremental above/beyond that of RoHS compliance. However, that's not true where substances facing authorization and eventual restriction is concerned, like the phalates (e.g. DEHP) for instance. Cost becomes significant somewhere along the supply chain for that.

As far as ease of determining the cost early, see the next part of the post. Preview: today it's not falling-off-a-log easy, if you want to do it right. But it's far from impossible or even difficult.

jbond
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re:
jbond   2/27/2012 11:43:02 AM
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I wasn't aware of one of the specific ingredients, my husband works for a large chemical company involved in this. He said what I was refering to is a cyclic methylsiloxane. There are 2 main ones, octamethylcyclotetrasiloxane (also known as D4) and decamethylcyclopentasiloxane (D5).

Studies said that D4 was potentially toxic and can wash off from hair and skin and build up in the marine environment. They replaced it with D5, and now some governments like Canada were saying that D5 might be bioaccumulative also. There is no direct replacement for this ingredient.

He did say that the EU and Canada have recently backed off of their stance regarding this issue, but companies are still looking for viable alternatives.

Michael Kirschner
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Michael Kirschner   2/27/2012 11:26:04 AM
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Products and formulas only have to change due to the REACH regulation when substances are entered into Annex XVII, or your supply chain needs - but does not have - authorization to use a substance listed in Annex XIV.

I'm not aware of any "silicones" on the SVHC list; in any case it's up to manufacturers to determine whether to remove an SVHC substance from a product and, if they do, determine how to replace it such that the product keeps key properties...if they want to keep selling the product. California's Safer Consumer Products regulation will address this more directly than REACH does. Stay tuned.

Are there SVHCs that were not well researched? Which are they?

Michael Kirschner
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Re: Common Sense
Michael Kirschner   2/27/2012 11:18:39 AM
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Thank you, but it is up to the manufacturer how they want to address the cost of compliance. It can come out of profit, be added to priced, be pushed back upstream (and possibly hidden to return as product cost or quality cost), or taken advantage of. See the next part of my post. Quality, by the way, should not be a cost - it must be designed in. This is classic problem prevention - again not nearly as glorious as problem solving (which requires a problem to occur first) but not nearly as costly.

WaqasAltaf
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Re: Common Sense
WaqasAltaf   2/27/2012 11:13:15 AM
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"So it depends on the customers in th end, are they really ready to sepnd money for quality and regulatory compliance."

@eletronx_lyf

So true. I have heard many of the executives say that on media that if customers are willing to accept the cost burden of regulatory compliance, we are ready to fully comply. Also, as jbond is mentioning, its not only the price factor but also some products have to be modified for bad. So it will be a very hard decision for companies to comply with the regulation as always it has been to comply with earlier regulations. However, while this is true, its also not false to say that many of the companies have unreasonable profit margins. Probably its time for them to compensate society without transferring the cost to consumers.

Bolaji Ojo
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Re: Common Sense
Bolaji Ojo   2/27/2012 8:07:38 AM
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Michael, Cost is a concern always when it comes to ensuring compliance with rules and regulations especially in the case of REACH. In your opinion, how expensive is it to become REACH compliant and how easy is it for companies to determine the cost early?

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