REACH Regulation and Supply Chain: Ensuring Chemical Compliance for Stainless Steel Parts

As global distributors and OEM brands sourcing stainless steel parts from Caffepress, you understand the critical importance of regulatory compliance. The Registration, Evaluation, Authorisation and Restriction of Chemicals (REACH) regulation (EC No 1907/2006) is a cornerstone of chemical safety within the European Union (EU) and the European Economic Area (EEA). This article provides a detailed overview of REACH, its implications for your stainless steel supply chain, and how Caffepress ensures compliance to help you meet your obligations.

Understanding REACH and Its Scope

REACH aims to protect human health and the environment from the risks posed by chemicals. It places the responsibility on manufacturers, importers, and downstream users to ensure that chemicals they produce and place on the market are used safely. The key components of REACH include:

• Registration: Manufacturers and importers of chemicals in quantities of one tonne or more per year must register them with the European Chemicals Agency (ECHA). This involves submitting comprehensive information on the properties of the substance, its uses, and how it can be used safely.
• Evaluation: ECHA and Member States evaluate the information submitted in registrations to verify its accuracy and assess the risks posed by the substance.
• Authorisation: Substances of Very High Concern (SVHCs) that pose unacceptable risks to human health or the environment may be subject to authorisation. This means that companies can only use these substances if they have been granted authorisation by ECHA for specific uses.
• Restriction: Substances that pose unacceptable risks can be restricted from being placed on the market or used in specific applications.

Importantly, REACH applies not only to chemical substances but also to substances in articles. An “article” is defined as an object which during production is given a special shape, surface or design which determines its function to a greater degree than does its chemical composition. Stainless steel parts clearly fall under this definition.

REACH and Stainless Steel: Key Considerations

While stainless steel itself is generally not considered a substance that requires registration, certain elements or compounds used in its production or present as impurities may be subject to REACH regulations. The primary areas of concern within the stainless steel supply chain are:

1. Substances of Very High Concern (SVHCs) in Stainless Steel

SVHCs are substances that have hazardous properties, such as being carcinogenic, mutagenic, reprotoxic (CMR), persistent, bioaccumulative and toxic (PBT), or very persistent and very bioaccumulative (vPvB). If an article contains an SVHC above a concentration of 0.1% weight by weight (w/w), the supplier has a duty to communicate sufficient information to allow safe use of the article to its customers.

Typical concerns regarding stainless steel include:

• Nickel: A common alloying element in stainless steel, nickel is also a known sensitizer and can cause allergic contact dermatitis. While nickel is not currently on the Authorisation List, it is subject to restrictions under REACH, specifically concerning its release from products that come into prolonged contact with the skin.
• Chromium VI compounds: These compounds can form during certain stainless steel processing operations, such as welding or surface treatment. Chromium VI is a known carcinogen and is strictly regulated under REACH.
• Other potential SVHCs: Depending on the specific grade of stainless steel and the manufacturing processes used, trace amounts of other SVHCs may be present. Caffepress proactively monitors the ECHA Candidate List of SVHCs and adjusts its processes accordingly.

2. The Supply Chain Communication Obligation

REACH places a significant emphasis on communication throughout the supply chain. As a distributor or OEM brand, you need to be aware of your responsibilities to communicate information about SVHCs in the stainless steel parts you receive from Caffepress to your own customers. This includes providing information on:

• The name of the SVHC.
• The concentration range of the SVHC in the article.
• Safe use information, including any precautions that need to be taken to minimize exposure to the SVHC.

Caffepress is committed to providing you with the necessary information to meet your communication obligations. We provide Safety Data Sheets (SDS) and Declarations of Conformity for all our stainless steel parts, detailing the composition of the material and any relevant information about SVHCs.

3. Import and “Importer” Definition

If you directly import stainless steel parts from Caffepress into the EU/EEA, you are considered an “importer” under REACH and have certain obligations. This includes ensuring that the parts you import comply with all applicable REACH requirements, including the registration of any substances that are required to be registered. However, because Caffepress fulfills this requirement, distributors generally do not need to register on their own. Nevertheless, distributors and OEMs have due diligence requirements to trace the origin of their materials to make sure they comply with REACH regulations.

Caffepress’ Commitment to REACH Compliance

Caffepress recognizes the importance of REACH compliance and is committed to ensuring that all our stainless steel parts meet the requirements of the regulation. Our comprehensive REACH compliance program includes:

• Supplier Due Diligence: We carefully vet our suppliers to ensure that they are REACH compliant and that they use only approved materials and processes.
• Material Testing: We conduct regular testing of our stainless steel parts to ensure that they do not contain SVHCs above the 0.1% w/w threshold.
• Continuous Monitoring: We continuously monitor the ECHA Candidate List of SVHCs and update our processes and materials as needed to ensure ongoing compliance.
• Clear Communication: We provide clear and comprehensive information to our customers about the composition of our stainless steel parts and any relevant information about SVHCs. This includes readily available SDS and Declarations of Conformity.
• Traceability: We maintain full traceability of our materials throughout the supply chain, allowing us to quickly identify and address any potential compliance issues.

Summary

REACH is a complex regulation that requires careful attention to detail. By understanding the requirements of REACH and working with a compliant supplier like Caffepress, you can ensure that your stainless steel supply chain meets all applicable regulations and protects human health and the environment. Caffepress is dedicated to providing you with the highest quality, REACH-compliant stainless steel parts and the information you need to meet your regulatory obligations. Contact our customer support team for any additional questions or support.