What is REACH?

REACH  (Registration, Evaluation and Authorization of CHemicals) - The European Union’s new draft directive that will create a single system that will require manufacturers and importers of chemicals to register them along with the information needed to handle them safely. This “new” E.U. chemicals policy will do away with the 40 individual legislative policies that currently govern chemicals in the European Union. The primary goal of REACH is the protection of the environment and corresponding human health; the easy access of chemical toxicity data by the general public; and the proliferation of this ideal throughout the world by leveraging their position with existing and potential trading partners in the World Trade Organization.

Importance of the 1981 Cut off Date for EU New Chemicals Policy:

REACH legislation requires that all E.U. manufacturers and importers of chemicals that have been on the market prior to September of 1981 comply with REACH under the “no data, no sale,” green policy throughout the European Union. Thus, in the passive component supply chain, those chemicals that make up the capacitors, resistors and inductors that would be affected would be numerous because many of these chemicals are still in use. However, for every chemical involved in the production of passive components, there are just as many arguments for exemption.

What Passive Component Manufacturers will be required to do?

REACH draft legislation requires that all manufacturers or importers of chemical substances already on the market prior to September 1981 to collect as much human and environmental health risk data as possible on each chemical they either manufacture or import for consumption. The data will be used by the manufacturer or importer to manage the potential risks of the chemical, and to be forthcoming on the exact nature of its toxicology.

Passive Component Products that may be affected:

It is difficult to say without a doubt which passive component parts will be affected but it appears, based upon my analysis, that the process will separate more advanced components from less advanced components. A closer look at some products may shed some light.

Tantalum Capacitors: Tantalum capacitor powder is not necessarily a chemical, but rather an element on the periodic table so it may be exempt. Currently, as the draft exists, all metals and alloys are currently included, but there is considerable movement to get large tonnage materials taken off the list. Both petroleum and polymers have been taken off the list, so other industries are compelled to get their materials taken off the list. Tantalum will certainly be scrutinized regardless as it has been in use by telephone companies since the 1960s. However, the cathode material, based upon traditional manganese nitrate chemicals, would also be subjected to REACH. Tantalum capacitors using conductive polymer would not have to comply with REACH for the cathode, but only for the tantalum anode, so this suggests a flawed system where part of a material joined with another material may mean that toxicity data is required for one part of the chemical but not the other.

Aluminum Capacitors: These would be keenly affected by REACH legislation as etched anode and cathode foil with chemical liquid electrolyte has been in existence since the first television sets were manufactured in the 1940s. Once again, the cathodic bath chemicals for etching the foil, and of course, the liquid electrolyte would be subject to REACH. However, electrolytes developed after 1981 would not be affected and neither would the conductive polymer aluminum capacitors. Fortunately for aluminum capacitor vendors, the aluminum industry as a whole is already collecting data in anticipation of REACH and this information, theoretically, will be available to the aluminum capacitor vendors, thus limiting their workload.

Ceramic Capacitors: Since ceramic capacitor manufacturers mix chemical slurries and employ chemical pastes for electrode and termination, it is interesting how this might affect the ceramic capacitor industry. Basically, the barium carbonate, titanium dioxide and barium titanate materials would not be exempt, as they would have been used in through-hole ceramic capacitors prior to 1981. Also, products containing palladium + silver would also have to be documented because of their large volume use prior to 1981, while ceramic capacitors using nickel and copper would have large data collections accomplished by the supportive industries and their related associations.

Film Capacitors: This is an interesting issue with respect to film capacitors because polymers are exempt. Thus, DC film capacitors are also exempt to some degree. This legislation, in some ways, favors DC film capacitors at the expense of other dielectrics.

AC Oil filled polypropylene capacitors no longer use PCB electrolytes, so they may also be exempt, although some of the motor run and microwave oven capacitors may contain chemical electrolytes that would have been in use prior to 1981. There are many alternative electrolyte solutions that have been developed after 1981 that could easily be used.

The Implementation of REACH

It is believed that REACH will begin implementation sometime in 2007 and will begin with large quantity substances manufactured or imported weighing in excess of 1,000 tons or more. This process should take three years. In 2010 registration for chemical substances manufactured or imported is required for products consumed in quantities of 100 tons or more, and between 2013 and 2018 the registration of substances with consumption volumes of 1 ton or more.

Requirements and Sustainability of REACH Data Collection

REACH requires that vendors at each stage of the supply chain add data to the chemical as they increase its value, and then by nature, add to its toxicity, so at the end of the electronic lifecycle, a massive quantity of environmental and human health risk data would have been collected and documented.

There are nine data points required for each individual chemical at each stage of the value-added process. The vision is that at each stage of engineered material production an additional dossier will be attached to the chemical as value and toxicity become layered to form a finished black box appliance. The most expensive and time consuming for manufacturers and importers to develop will be 1) Summaries of Annex V to IX Toxicity Data and 2) Studies of Annex Toxicity V to IX which will be time consuming and expensive in terms of man-hours required to collect this data and keep it organized.  Other dossier requirements are more basic of course and would include the 3) identity of the manufacturer or importer, 4) the chemical substance identity, 5) information on what it is used for (90% by weight); 6) Classification and Labeling; 7) guidelines for its safe use; a 8) statement on vertebrate animal testing and 9) proposals for further testing.

Downstream users of the chemical substances are required to visually inspect the REACH data dossier and ensure the material is the right chemical substance for their use. Once the substance has been established as part of the production process, then the handler must ensure the proper safety procedures are met to deal with the chemical substance. Additional documentation, including material data safety sheets, intended use documents, exposure scenarios, safety assessment and risk management data must be added to the chemical as it is moved downstream from its primary chemical form.

Costs of REACH to the Passive Component Industry:

The costs of REACH to the passive component industry will be high and will come directly from the bottom line, or the cost will be successfully transferred up the supply chain. The most costly portion of REACH will be the toxicity data collection. For certain large volume materials covered under the REACH program a substantial amount of toxicity data has been collected through trade associations and industry consortiums, most certainly for metals and alloys consumed in large volumes and meet initial REACH criteria of consumption greater than 1,000 tons, which had been in existence before 1981. Metals that are of extreme importance to the passive component industry, such as aluminum, nickel, copper and zinc have already begun massive, concerted international efforts to collect data on human health and ecological issues associated with these specific non-ferrous metals. Aluminum is of course the dielectric consumed in aluminum capacitors, so there is significant amount of data already being generated; nickel and copper are consumed in ceramic chip capacitors for electrode and termination respectively and these will be directly affected, but once again, a substantial amount of data collection is already underway involving these metals in preparation of the enactment of REACH. EU officials likewise are encouraging the international community to adopt REACH-like measures, and to begin data collection in areas where little data collection on chemical substances is done and the affects on human health and the environment is not known or as of yet transparent to the general public. EU officials are also encouraging manufacturers and importers of chemicals to already begin data collection processes for chemicals consumed in quantities less than 1 ton which were in existence since 1981 and thus prepare themselves early for the REACH legislation.

Without concerted efforts, the burden of individual materials vendors to the passive component industry may become dramatic, and costs required for funding toxicity studies could become burdensome and will either come from profits or be transferred up the supply chain along with the REACH dossier for further scrutiny and documentation.