REACH – What is in Your Products?

December 2009

Paula Etsy and Jamie White

Abstract: Do you have customers located in the European Union (EU)? Does your customer or customer’s customer sell products to organizations in
the EU? If either of these answers is yes, then the products that are being produced by photochemical machining processes within the manufacturing supply chain could be subject to the EU Registration, Evaluation, Authorization, and Restriction of Chemicals regulation, otherwise known as REACH. REACH is an EU regulation that defines the safety criteria for controlling chemicals (i.e., substances and preparations) and products (i.e., articles) through the entire supply chain from raw materials, to users, to the final industrial or consumer product. The REACH regulation bans substances, sets the criteria for certain uses of substances, and requires communication on the safe use of substances and articles.

REACH is a highly complex regulatory requirement. Organizations that are based in the EU need support from the supply chain in order to determine their regulatory risk. Organizations need to determine if they are regulated, where they are regulated, and what is needed for a compliance plan to minimize their risk. To determine the risk, the REACH regulation drives EU-based organizations to pass the REACH requirements down the supply chain which includes United States (U.S.) based corporations. The requirements are being passed down via contractual obligations, customer survey of compliance, and customer procedures or drawing requirements. In order to meet customer expectations and demands, it is important to develop an understanding of what the REACH regulation is about.