Emerging regulations and standards are forcing the electronic sector to be as flexible as it is quick. And to excel, electronic companies need to overcome both existing and emerging regulatory challenges in the market. REACHLaw provides global compliance solutions to the electronic sector, to help it to succeed in their globalization efforts.
CASE 1: Lead Registrations
Electronic appliance manufacturer
Analysis of alternatives; Socio-Economic Analysis; Chemical Safety Report
Sodium chromate has been included in the REACH authorisation list with a sunset date in September 2017. The company applying for authorisation produces goods for mobile comfort lifestyle, and the substance listed for authorisation is essential for the function of a specific product of the applicant. A use-specific Analysis of Alternatives and Socio-Economic Analysis for authorisation were prepared to ensure continued use after the sunset date as long as required.
REACHLaw collected information from the client and based on that information formulated a realistic non-use scenario for the joint AoA and SEA report.
The dossier is at the moment available for commenting at ECHA website.
CASE 2: Scoping studies on the impact of inclusion of Lead metal on the Authorisation List
Manufacturers of lead sheeting engineering products
Weather protection, radiation shielding, lead-lining, metals & alloys, counterweights & ballast, ordnance
Scoping studies on the impact of inclusion of Lead metal on the Authorisation List
Lead metal: candidate for inclusion on the Authorisation List
An entry for lead metal is on the candidate list for inclusion on the Authorisation List since 2018. We assisted a group of companies who make lead sheeting engineering products for diverse sectors scope authorisation requirements for use of their products by their customers. A key finding of our scoping study was that lead engineering products are widely used in diverse sector and that alternatives proposed for many of these uses are not available in the quantities needed and many are on the EU critical raw materials list. In addition, due to absence of alternatives, potentially 1000’s of applications for authorisation would need to be submitted depending on where the transition from “substance” to “article” is made.
We assisted the group of companies provide input in both the ECHA public consultation on its 11th draft recommendation to include an entry for lead metal on the Authorisation List. We also assisted them submit detailed information in Commission parallel public consultation on the socio-economic impacts for each of its seven use categories.
Contact us for more information on our authorisation services at firstname.lastname@example.org
CASE 3: Advocacy support services - Electronics
Electronic component manufacturer
Preparation of contribution to public consultation
The European Commission launched a public consultation on restriction proposal for Perfluorooctanoic acid (PFOA), PFOA salts and PFOA-related substances. A substance included in this category is used in the manufacturing process of electronic components by a DU company.
REACHLaw prepared a DU company specific comment comprising of a realistic non-use scenario, Socio-Economic Analysis and Analysis of Alternatives. The arguments used were in line with the comment from the industry sector representative. Based on the comment, ECHA committees proposed to exempt the use of the PFOA-related substance in electronic component manufacture without a review period.
The reviewed restriction proposal is currently undergoing public consultation.