Managing material compliance risks - REACH and RoHS

TABLE OF CONTENTS


I. What do REACH and RoHS stand for?

The Registration, Evaluation, Authorization and Restriction of Chemicals Regulation (EC) 1907/2006, short REACH, regulates the production and use of chemical substances, and their potential impacts on both human health and the environment.

The Restriction of Hazardous Substances Directive, short RoHS Directive, aims at restricting the use of certain hazardous substances in electrical and electronic equipment. It regulates their use and placement on the European market and requires manufacturers to replace these substances in their products with less hazardous alternatives.

II. What REACH and RoHS information can I collect with the platform?

The platform offers two ways to collect REACH- and RoHS-related information from suppliers:

a) The REACH and RoHS Topics of the Maturity Assessment enable a high-level assessment of material compliance risks at the company level on the supplier side.

b) The Product Mapping Request enables the targeted collection of product-level material compliance information and proof documents from suppliers.

Case I. REACH and RoHS Topics of the Maturity Assessment

Your company can request its suppliers to answer the REACH and/or RoHS Topics of the Maturity Assessment:

1. By selecting these topics upon invitation of the suppliers via connection request

2. By sending a Maturity Assessment Request at any later point in time

 

Scope of the Assessment Topics:

  • Only company-level material compliance information is collected within the assessment topics.
  • Since compliance must be demonstrated at the product level, providing a proof document at the company level is optional.
  • Suppliers are asked to confirm that they are not placing on the market any products containing respectively (i) critical substances according to REACH regulation (EC) 1907/2006 or (ii) restricted hazardous substances according to the EU directives 2011/65/EU (RoHS 2) and 2015/863/EU.
  • If they place products containing substances subject to the above-mentioned regulations on the market, they will be asked whether the concentration of these substances in the product exceeds the legal thresholds.
  • Only if the legal thresholds are exceeded will suppliers be asked to confirm that they have listed the products in question on the platform. However, the products are listed as independent items in the dedicated product menu and not linked to the respective assessment topic.
  • Procurement teams may use these Assessment Topics to obtain a high-level risk assessment of material compliance risks at the level of supplier companies, for instance as part of their supplier selection/qualification processes.
  • Neither product managers nor compliance or quality assurance teams should expect these Assessment Topics to provide them with proof of compliance at the product level or to enable continuous monitoring of material compliance.

Case II. Product Information Request

Your company can request its suppliers to list specific products they supply to your company by sending them a Product Information Request.

 

Scope of the Product Information Request:

  • Mandatory product-level information relevant to material compliance:
    • Product details (product name, product identifier, etc.)
    • The component(s) purchased by your suppliers to produce the listed product.
  • Optional product-level information relevant to material compliance:
    • Information on REACH substances present in the product in a concentration that exceeds the legal thresholds (0.1 %).
    • Information on RoHS substances present in the product in a concentration that exceeds the legal thresholds (0.01 % for Cadmium and 0.1 % for all others).

Product managers or compliance and quality assurance teams may use the Product Mapping Request to collect product-level information relevant to material compliance for products containing substances subject to the REACH regulation or the RoHS directive in a concentration that exceeds the legal thresholds (0.1 % in most cases).

 

Use the "Instructions" field of the Product Information Request to communicate your requirements to your suppliers regarding the scope of product information you expect them to provide:

  • Scope in terms of products to be listed:
    • All the products they supply to your company.
    • The products they supply to your company containing substances subject to the REACH regulation or the RoHS directive in a concentration that exceeds the legal thresholds (0.1 % in most cases).
  • Scope in terms of product information to be provided:
    • Material compliance proof documents at the product level via the "Attachments" field of the product details