Hazardous Chemical Declarations means the requirement for all suppliers located in the EU to provide recipients of “articles” (any item with a specific shape such as equipment, components, spare parts, packaging, etc.) with information on any Substances of Very High Concern (SVHCs) present at more than 0.1% by weight. The addition of Lead to the Candidate List in 2019 greatly increased the likelihood of an SVHC being present in products. The number of SVHCs now exceeds 200 and more are being added every six months. It is increasingly difficult and time-consuming to obtain and process the information for compliance.
The standard method of obtaining SVHC information is to ask suppliers. As even small manufacturers can have many thousands of parts in their products, and tens of thousands of simple articles within them, this is a costly and time-consuming task with typically low response rates and poor-quality data obtained.
Our award-winning approach is to narrow down to only those SVHCs which are likely to occur in each type of material, component and complex assembly. This analysis can cover all types of items that are used and supplied including packaging, batteries and chemicals such as adhesives.
Our engineers have spent many thousands of hours gathering information on where SVHCs are used and whether they are likely to exceed 0.1% in simple articles based on their knowledge of processes, chemistries and the materials used in articles. Using this extensive database of information as a foundation and backed by our in-house chemical expertise, we have developed a range of solutions which are designed for individual client’s specific types of products.
We have developed a system-to-system reporting tool that enables rapid reporting to the EU SCIP database.
Our fully-equipped laboratories provide in-depth testing of products and components in support of identifying restricted or reportable substances.
The following is a non-exhaustive list of legal requirements applicable to certain products and substances/mixtures in certain applications. Showing compliance is often through the use of appropriate standards which are not listed. This list focuses on EU requirements but somewhat analogous requirements often exist in other jurisdictions. In general, UK requirements remain largely aligned with those in the EI but there are significant differences and divergence over time is to be expected.
Type | Title of legislation | Ref. | Jurisdiction |
Chemical/ environmental | Restriction of certain Hazardous Substances (RoHS) Directive | 2011/65/EU | EU/EEA |
Chemical/ environmental | REACH Regulation | 1907/2006 | EU/EEA |
Chemical/ environmental | Food Contact Materials Regulation | 1935/2004 amended by 2019/1381 | EU/EEA |
Chemical/ environmental | Stockholm Convention | International | |
Chemical/ environmental | Toxic Substances Control Act (TSCA) | US Federal | |
Chemical/ environmental | Batteries Directive | 2006/66/EC amended by 2013/56/EU | EU/EEA |
Chemical/ environmental | Ecodesign (Framework) Directive – and implanting regulations | 2009/125/EC | EU/EEA |
Chemical/ environmental | Classification, Labelling and Packaging Regulation (CLP) | 1272/2008 | EU/EEA |
Chemical/ environmental | Biocidal Products Regulation | 528/2012 | EU/EEA |
Chemical/ environmental | The Fluorinated Greenhouse Gases (F-Gas) Regulation | 517/2014 | EU/EEA |
Chemical/ environmental | The Persistent Organic Pollutants (POPs) Regulation | 2019/1021 | EU/EEA |
Chemical/ environmental | Waste Electrical and Electronic Equipment (WEEE) Directive | 2012/19/EU | EU/EEA |
Chemical/ environmental | Proposition 65 | California | |
Chemical/ environmental | Waste Framework Directive - SCIP | EU/EEA | |
Both | Toy Safety Directive | 2009/48/EC | EU/EEA |
Technical | Low Voltage Directive (LVD) | 2014/35/EU | EU/EEA |
Technical | Radio Equipment Directive (RED) | 2014/53/EU | EU/EEA |
Technical | Electromagnetic Compatibility (EMC) Directive | 2014/30/EU | EU/EEA |
Technical | Pressure Equipment Directive (PED) | 2014/68/EU | EU/EEA |
Technical | Simple Pressure Vessels Directive | 2014/29/EU | EU/EEA |
Technical | Personal protective equipment (PPE) Regulation | 2016/425 | EU/EEA |
Technical | Equipment for potentially explosive atmospheres (ATEX) | 2014/34/EU | EU/EEA |
Technical | Machinery Directive | 2006/42/EC | EU/EEA |
- Understanding requirements that apply to a particular type of product placed on the market in a certain jurisdiction – and what to do as a result
- Keeping up to date with changes in existing requirements and emerging new ones. Understanding how to respond.
- Understanding upcoming obsolescence issues caused by restriction of chemical substances (e.g. RoHS, REACH, TSCA) and avoiding regrettable substitution.
- Assessing presence of Substances of Very High Concern (SVHC) in products and components.
- Eco-design and sustainability
- Chemical content testing or technical analysis
- Understanding end-of-life obligations (e.g. WEEE, batteries)
- Demonstrating conformity
- Assessing safety/risk
- Responsible sourcing (conflict minerals)