LONDON A survey has thrown up major concerns that the recently adopted EU REACH (Registration, Evaluation and Authorization of Chemicals ) regulation will disrupt metal and chemical supply to the EU and this could start to cause major disruptions by the end of this year if importers do not begin to take action to deal with the regulation.
The worrying results of the survey, conducted by IPC Market Research, suggest that the majority of solder suppliers have very limited knowledge of the regulations. When asked about awareness and readiness for REACH compliance, most scored a 1 (none) in response to a 10 point scale.
This is a worrying and surprising statistic with less than 3 months for pre-registration under REACH, according to IPC.
Companies may not understand that the implications of not being REACH compliant could lead to exclusion from the EU market, thus resulting in inevitable interruptions in trade.
REACH is expected to impact every company within the EU, especially those depending on non-EU suppliers.
However with little or no understanding of how REACH will affect their businesses, and with the first REACH deadline looming at the end of November, there are serious concerns that compliance will not be achieved within the required timescales. This, the survey suggests, is particularly evident in the electronics solder supply chains.
"While supply of tin ingots to the EU should continue fairly smoothly due to the actions already taken by metal producers to pre-register, little is known of the plans of tin alloy or solder importers in the EU," comments Kay Nimmo, Manager of Environmental Affairs at ITRI and Secretariat to the REACH Tin Metal Consortium.
"Tin, as well as other metals in alloys imported as bar, wire, and/or paste would all need to be pre-registered under REACH by the EU importer or a representative on behalf of the non-EU producer. It is a concern that only a few solder companies have so far pre-registered for import of tin in alloy form".
The REACH regulation came into force last June and aims to ensure that information is available on all chemicals and metals manufactured and/or used in the EU, in order to minimize any possible risk to human health or to the environment from these products. Pre-registration, the first requirement of REACH, involves submitting a brief set of information to the Agency, and enables manufacturers and importers to benefit from extended registration deadlines depending on the tonnage band.
Companies failing to pre-register their substances before 30th November 2008 will have to suspend manufacture and/or import of those substances straight away. They will need to attempt to register them (with a considerable amount of toxicological, use and exposure related information which may not be immediately available) which will lead to inevitable disruption of the supply chains.
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