Besides registration, you should also pay attention to the direction of REACH development after 2018. After 2018, the European Chemicals Agency (ECHA) will require companies to maintain and update their registrations and will continue to conduct substance assessments and inquiries, authorizations and restrictions, and audits of CLP regulations and safety data sheets. As a finished product supplier, companies may face obligations related to finished product registration, notification, or supply chain communication. In July 2013, REACH enforcement agencies (including Belgium, Denmark, France, Germany, Norway, and Sweden) published compliance guidelines for substances of very high concern in finished products. Regarding supply chain communication, the recommended practice is that if finished products contain >0.1% (w/w) SVHCs, whether sold individually or assembled, consistent information should be provided. Furthermore, if assembled products contain SVHCs, the information should include where the SVHC is located and be easily communicated throughout the supply chain. It is worth noting that on September 10, 2015, the European Court of Justice ruled that the calculation of 0.1% (w/w) SVHC should be based on individual finished product parts. For example, in the case of a shirt, the SVHC content of the fabric, buttons, and sewing thread should be calculated separately, rather than using the entire shirt as the unit of calculation. To comply with the requirements for information communication within the REACH supply chain, companies are advised to analyze information provided by suppliers and adhere to the following principles to help focus on finished products that may contain SVHCs: 1. When initially assessing the presence of substances of very high concern in finished products or finished product parts, companies can start with the raw materials; 2. Further assess which raw materials may contain which substances of very high concern. For example, plastic bicycle handlebar grips may contain plasticizers; 3. Proceed gradually with suppliers who handle complex finished products. This not only facilitates information dissemination but also verifies the collected information through analysis and testing. Furthermore, seeking inter-industry cooperation not only identifies which SVHC substances may be present but also accelerates the REACH information dissemination process. Utilizing tools and routinely verifying REACH information communication is crucial. This includes things like material confirmation lists during product development, using standardized forms during procurement, signing agreements and contracts with customers, requesting third-party verification and product test reports, and conducting supplier audits. As more SVHCs are added to the candidate list, this process enables businesses to effectively manage complex substance information, benefiting suppliers handling complex finished products. Furthermore, businesses should establish quality management systems to promote the fulfillment of REACH information communication obligations and continuously add SVHCs, as the responsibility to notify downstream customers takes effect immediately after a substance is added to the list. Businesses should then notify the European Chemicals Agency within six months and respond to SVHC requests from consumers within 45 days. Denmark, Sweden, and Germany have all released mobile apps allowing consumers to request safety information from businesses regarding SVHCs in their products. This aims to accelerate the standardization of finished product supply chain communication under the EU REACH regulation. The Industrial Development Bureau of the Ministry of Economic Affairs reminds Taiwanese manufacturers exporting to Europe to actively implement corresponding strategies to protect their commercial interests. For detailed definitions and case studies of finished products, please refer to the attached document: Guidance for suppliers of articles_en.pdf
