In this continuing series on resources and services related to the European Union's environmental protection regulation known as REACH, for Registration, Evaluation, Authorization, and Restriction of CHemical substances, I have covered some key providers including GreenSoft Technologies, Design Chain Associates, Total Parts Plus, and EEContent.com.
I also mentioned a few others that, like EEContent.com and TPP, provide not just REACH data but also email push alerts for EOL, PCN, and other time-critical component notifications. (See: REACH Scrubbing? Try Total Parts Plus and REACH, RoHS, EOL, PCN Resources & Services, Part 1.)
A few weeks ago I interviewed Sitmae Reach Services BV based in the Netherlands. This is a father-daughter team, and as the interview progressed, I began to appreciate the niche that these two entrepreneurs had carved out for themselves. REACH is a very expansive and extensive program, and just trying to grasp the basic legislation has been a real chore for me. However, Sitmae has greatly simplified that task with a well written overview and easy-to-read documentation, which includes step-by-step guidance to compliance.
Sitmae's Website itself can serve as a valuable REACH learning resource. The site guides customers through the procedures for enlisting Sitmae's services, which include, but are not limited to, determining if an item is an article or a substance or both. It was a surprise to me to learn that a candle is not an article; it melts and is therefore reduced to a substance. The difference between an article and a substance is determined by the composition of the product. A scented greeting card, for example, is not just a simple product but is defined as an article that releases a substance — making it both an article and a substance. Why is this important? Articles do not require pre-registration or registration, while substances do.
So the process involved in filing for REACH certification is substantially different by classification type. You tell me: Is a thermometer an article, substance, or mixture of both? To be sure, ask yourself if the mercury (substance) is intended for release? These are the kinds of issues that can be very confusing under the REACH regulation and that Sitmae specializes in helping customers categorize. So, what about mercury switches? We're back into electronics here. Do I need to pre-register these switches with REACH? This article/substance differentiation is just the first step in determining filing requirements.
Sitmae also produces material safety data sheets (MSDSs) in more than 20 European languages, providing translations based upon standard phrases in exactly the required EU REACH formats. It will organize the distribution of all of the safety MSDS documents and keep the required records up to date, being mindful of all REACH regulatory changes.
The company has developed a compliance method for REACH and articles. It uses a proactive non-testing method as recommended by the European Chemicals Agency (ECHA). European companies can stay anonymous from the public under REACH. As a third-party representative, Sitmae handles all the pre-registration and registration of its customers' substances under the Sitmae name. Only “Sitmae” will be shown as the registrant of the substances in the public databases.
Because manufacturers and importers of non-registered substances must notify ECHA of their proposed classification and labeling, Sitmae will work with ECHA on behalf of its customers. A non-European company — exporter or manufacturer — has to decide who is going to take on the REACH compliance burden. Only European legal entities may pre-register and register under REACH. Consequently, a non-European producer has to make a choice: Leave REACH compliance completely to your European customers (the importers) or employ what's referred to as an Only Representative to take away the customer's burden. Sitmae services include “Only Representative” as a standard offering.
Of all the companies mentioned at the beginning of this article, Design Chain Associates is one of the most capable consulting firms for training and educating a company on REACH management, procedures, and processes and is based in the US. Sitmae is the EU-based company that will actually handle all the classification and registration work required to facilitate a European or non-European company's product or substance registration with ECHA.
This is a service that is desperately needed as US companies come up to speed with REACH requirements while struggling through the lugubrious process of educating themselves on the legislation that will determine whether they will be able to have a presence in the European marketplace in the not too distant future.