German Environment Agency Seeks Information From Article Suppliers Regarding REACH Article 33


25 September 2018

chemical testThe German Environment Agency (UBA) is one of the leading organisations behind AskREACH, a project aimed at raising awareness on Substances of Very High Concern (SVHCs) in articles among the European population, retailers and industry.

Project objectives include:

  • Raising consumer awareness on SVHCs in articles, to enable consumers to make responsible purchasing decisions;
  • Raising article supplier awareness on compliance with REACH information duties;
  • Improving the information flow on SVHCs between consumers and suppliers; and
  • Improving supply chain communication processes that ultimately aim at substituting SVHCs in articles.

A project deliverable is the development of a “European database which will be continuously filled with information on SVHCs in articles by suppliers”. The UBA is looking to article suppliers to share relevant information, suggesting that “participating suppliers will receive valuable assistance by gaining access to another IT tool under development that facilitates communication in the supply chain”. At present, the UBA is seeking to understand how article suppliers comply with REACH Article 33 requirements, specifically whether suppliers obtain information via one or more of:

  • Requesting information from suppliers;
  • Requesting evidence that information shared by suppliers is genuine and correct (e.g. by asking for the results of chemical testing);
  • Using contracts to get suppliers to share SVHC information;
  • Performing risk assessments;
  • Obtaining third party certification(s);
  • Sample testing articles for the presence of SVHCs.

The UBA is also asking questions of article suppliers regarding another project deliverable, a proposed Europe-wide smartphone app for consumers to launch requests pursuant to REACH Article 33.

It is envisaged that the app will be connected to a newly developed database with information on SVHCs in articles, the intent being to “ease and speed up responses by suppliers”. In this regard, the UBA is interested in suppliers’ opinions including whether companies consider SVHCs to be “only a small part of the problem”, that any app/database would “give the impression that companies are using banned substances, even though that is not the case” or that “production processes and related supply chains are too complicated to allow for companies to have this information for all articles”. These are just some of the UBA’s suggested opinions that suppliers are invited to agree or disagree with as well as substantiate with additional comments.

If you are an article supplier, you may take an interest in responding to the survey or else reading up on the project (quoted text in this article comes from both the survey and the “EU LIFE project: AskREACH” website). Relevant websites are:

https://www.umweltbundesamt.de/en/template/askreach-survey-for-companies

https://www.askreach.eu/

 

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Written by Dr Alex Martin

Dr Alex Martin, Senior Regulatory Consultant, RINA Alex is a technical professional with over 10 years’ experience working on product regulation, standards and policy issues in the UK and internationally. The focus of this work has been largely environmental, covering the likes of batteries, biocidal products, ecodesign, energy labeling, packaging, REACH, RoHS, timber sustainability and WEEE. Alex is also knowledgeable on a range of EU and UK product safety and consumer protection legislation (e.g. GPSD, LVD, PPE, toy safety, textile and footwear materials, product liability and guarantees) and quality, environmental and social compliance management standards.