Chemicals in products pose the next big risk for manufacturersBy John Wagner, AEM Director, Materials Management, and Michael Wurzman, President, RSJ Technical Consulting  

Can your company identify every chemical in every material in every part of every product that it manufactures ? Does your company know where those chemicals are used in your products, at what concentrations and for what purposes?

In today’s regulatory landscape, knowing this detailed information is absolutely critical. Failure to do so can result in substantial financial risks, including the loss of individual customers or even entire markets and governmentally imposed fines and penalties.

Requirements for Knowing Chemical Content

The products you manufacture likely contain hundreds, if not thousands, of individual parts. Each of these individual parts are made from a wide variety of materials such as plastics,  textiles and metals. In turn, each of these materials are made up of a number of individual chemical substances.

Depending on what you manufacture and where and who it is sold to, your company is responsible for knowing the chemicals that make up the parts or products that you sell. To cite just a few examples of what types of materials and chemicals are regulated:

  • There are limits on lead and other alloying elements that can be found in machining metals.
  • There are restrictions on the amount of of cadmium found in paints, plating and plastics.
  • There are restrictions on numerous additives that are found in plastics. Plastics like Nylon, ABS and PVC typically contain 10 to 20 additivies that impart desired properties such as UV and corrosion resistance; it is in these additional additives that we find the majority of the substances that are restricted or banned by some countries/areas of the world. To ensure continued market access, manufacturers must know where and at what concentrations regulated chemicals are found.

In certain instances, manufacturers are required to report to government agencies if their products contain specific chemicals and/or to communicate this information to end-users.

Legislative and Business Context

Governments are aggressively reducing the negative impacts on human health and the environment by passing laws that limit the amount of certain chemicals found in articles (parts and products). As a result, virtually every manufacturing company is being hit with a wave of new laws that target the chemicals in its products.

These laws not only impact companies that sell items on the consumer market, but also impact the suppliers of such companies as they will increasingly be asked to provide chemical content information for the parts that they sell to such companies.

Product chemical content laws that impact the equipment industry include, but are not limited to:

  • Restrictions of Hazardous Substances (RoHS) Directive
  • European Union (EU) Registration, Evaluation and Authorization of Chemicals (REACH)
  • U.S. Conflict Minerals law
  • U.S. Toxic Substance Control Act (TSCA)

Furthermore, in just the last two years, there has been a string of rulings and enforcement actions that are defining the parameters by which companies will be evaluated; the regulatory compliance management process by which companies will be measured; and the sales, marketing and other opportunities that companies can leverage from their compliance activities.

Because of the seriousness of the above issues for AEM members and their suppliers, AEM will provide a series of Advisor articles that address the above legal and business risks, as well as industry-wide solutions that are being implemented to help reduce compliance costs, increase efficiency and accuracy, and ensure continued global market access.

 

 

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