Compliance to List of Declarable Substances (LoDS) · products ≥0.1%, customers have to be...

© Siemens AG 2010. All rights reserved.

Compliance to List of Declarable Substances (LoDS) Basis for REACH Art. 33

compliance

V1.0 2010-04-28

CSCM PS PG / CHR EHS EP PE© Siemens AG 2010. All rights reserved.

LoDS ComplianceV 1.0/ 2010-04-28

Overview

1 Legal Background

3 Compliance to LoDS

2 Implications for procurement



REACH regulation’s motto is: No data = no market!

New EU regulation with broad scope covering almost all chemicals REACH encompasses a series of registration, evaluation, and authorisation duties administered by the EChA1)

Relevant requirements for industry are listed below:

1)

European Chemicals Agency based in Helsinki 2)

SVHC can be either carcinogens, mutagens or toxic to reproduction, or persistent, bioaccumulative, and toxic, or very persistent and very bioaccumulative and are put on the candidate list for authorisation by ECHA

Registration When manufacturing or importing from outside the EU ≥1 tonne/year, the imported chemicals must be registeredTo take advantage of an extended registration deadline imports must be pre-registered. This deadline depends on the tonnage and hazard classification

Information When substances of very high concern (SVHC2)) are present in products ≥0.1% weight by weight, customers have to be informedThis information shall be received from suppliers and it needs to be passedalong the entire supply chain

Authorisation Applications related to certain SVHC require authorisationThese selected SVHC will be part of Authorisation List (REACH Annex XIV)

REACH, Art. 33



Chemical element and its compounds in the natural state or obtained by any manufacturing process

Mixture or solutioncomposed of two or more substances

Definition

Example

SubstanceSubstance MixtureMixture ArticleArticle

Copper powder

One product = 1 or more articles!

Acetone Granulated

plastic Wind turbine

(blades, tower, gearbox, etc)

Cables Circuit board

Paint

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

Registration Information

Registration scope is very broad, while information applies only to “articles”

http://images.google.de/imgres?imgurl=http://www.home-decorating-reviews.com/images/acetone_for_wood.jpg&imgrefurl=http://www.home-decorating-reviews.com/magazine/wood-furniture-care.html&usg=__TyKlBORKzzj6ODdz6MpqXSMgi9U=&h=300&w=225&sz=9&hl=en&start=17&tbnid=MSFrWNVrTT7DLM:&tbnh=116&tbnw=87&prev=/images%3Fq%3Dacetone%26gbv%3D2%26hl%3Den

http://images.google.de/imgres?imgurl=http://www.indiamart.com/nagpalenterprises/pcat-gifs/products-small/plastic-raw.jpg&imgrefurl=http://catalogs.indiamart.com/products/color-masterbatches.html&usg=__bWXnzVh9NOiNwLwoaPGgJu2Gd6s=&h=200&w=200&sz=13&hl=en&start=16&tbnid=OLD58xpZB8fd3M:&tbnh=104&tbnw=104&prev=/images%3Fq%3Dgranulated%2Bplastic%26gbv%3D2%26hl%3Den

http://www.signalmax.net/products/components/com_virtuemart/shop_image/product/b215032b029d3e36f047c6eae2c9b03b.jpg

http://images.google.de/imgres?imgurl=http://www.germes-online.com/direct/dbimage/50203337/Printed_Circuit_Board.jpg&imgrefurl=http://www.germes-online.com/catalog/87/394/58981/sell_printed_circuit_board.html&usg=__o1q4mJjlIGrPK9wXdsMf0yqBEtk=&h=360&w=360&sz=29&hl=en&start=16&um=1&tbnid=VovaHGnA5ToBbM:&tbnh=121&tbnw=121&prev=/images%3Fq%3Dcircuit%2Bboard%26hl%3Den%26um%3D1



Overview

1 Legal Background

3 Further information

2 Implications for Suppliers



………

…

……REACH Information Regulations Implications for Siemens Suppliers

Supplier plays a central role for achieving REACH Art. 33 compliance

Information

If substances of very high concern (SVHC) are present in products ≥0.1% weight/weight, customers have to be informed

Inform

Contracts

for delivery of relevant products1)

ought to be adapted

Substance declaration, based on LoDS2), must be completed and signed

and sent back to Siemens requestor3)

Contracts

1)these are products that fulfill the definition of article (see slide 4) 2)List of declarable substances (LoDS) covers European substance restrictions (see slide 7)3)either within c4s easy or return vial Mail or Email as received



The List of Declarable Substances -

outlines European substances restrictions like REACH & RoHS1)

RoHS

Regulation 2002/95/EG

Substances Restriction: e.g. lead, mercury, cadmium are prohibited in electrical & electronic products

REACH

Regulation 1907/2006

Substance Information:If REACH substances are present in products ≥0.1%, customers have to be informed

1)

RoHS = Restriction of (the use of certain) hazardous substances2)

European Chemicals Agency based in Helsinki

List of declarable substances (LoDS)

As the ECHA2)

intends to enhance the REACH candidate list every 6 months relevant suppliers must ensure to renew their declaration twice per year



Implemented Process ensures supplier commitment to the LoDS1)

through a general substance declaration

Process General Substance Declaration

1)

List of Declarable Substances2) www.siemens.com/scm/supplier/sq

Process

In general, Suppliers are qualified through Siemens wide mandatory SQ2)

process

General Substances Declaration is required as part of the EHS module within SQ process

Process will ensure that relevant suppliers commit to the Substance Declaration by signature

Substance Declaration request supplier to state whether products contain substances of the LoDS1)

http://www.siemens.com/scm/supplier/sq



For detailed product declaration1)

, BOMcheck

is the preferred declaration method for Siemens

Description

Advantages Disadvantages

Alternatives

BOMcheck is a substance declarations tool that enables suppliers to comply with the applicable REACH and RoHS requirementsEach supplier can enter the required substance data and make it available to the correspondent manufacturerEach supplier pays a subscription of 300 Euros per year to join BOMcheck (membership is free for small suppliers)Further information: http://www.bomcheck.net/

Low costs since membership is free for manufacturers provided they agree to send a letter to their suppliers to require them to comply with their REACH requirements by joining BOMcheck

Substance list does match all substances as listed in LoDS “List of declarable Substances”

Simple use of database

Annual Cost of 300 Euro

Siemens Format for electronic transfer of Substance Declaration

1)

detailed product declaration means substance information ≥0.1% weight/weight

for each product

http://www.bomcheck.net/

http://www.bomcheck.net/

https://w9.siemens.com/cms/supply-chain-management/en/supplier-at-siemens/basic-information/environment/product/Pages/stewardship.aspx



Overview

1 Legal Background

3 Further information

2 Implications for procurement



Further Information

Further Information

REACH Siemens website

Environmental Protection & Technical Safety for Suppliers

Information on restricted substance from suppliers

http://www.siemens.com/reach

https://w9.siemens.com/cms/supply-chain-management/en/supplier-at-siemens/basic-information/environment/Pages/basic-requirements.aspx

https://w9.siemens.com/cms/supply-chain-management/en/supplier-at-siemens/basic-information/environment/product/Pages/stewardship.aspx



Reach relevant information can be found online

As of Oct, 2009

General information on REACH

Contact email for e.g. suppliers

Candidate List

1)

1) see: http://www.siemens.com/reach

Presentation „Introduction to REACH“

http://www.siemens.com/reach



Information on BomCheck / Siemens Format

Substance Declaration / LoDS

General Information on REACH & RoHS

Reach-relevant information can be found online

Compliance to List of Declarable Substances (LoDS) · products ≥0.1%, customers have to be...

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