One of the biggest challenges faced by companies that use chemicals is obtaining information on substances from their suppliers – whether it is to check if substances are registered, or if materials and components contain SVHCs in quantities over 0.1% w/w. Many companies downstream have attempted to fulfil their obligations by sending letters or emails to their suppliers. Unfortunately it seems that, more often than not, those letters have gone unanswered.
While companies could switch from their current supplier to a more responsive one, that option is often not straightforward. Many companies have tried to build closer relationships in the supply chain, but, again, this might not be practical if those relationships span many hundreds, let alone thousands, of suppliers. Others have added obligations to contractual agreements, requiring suppliers to provide the information.
One compliance department at an agrochemical company found that engaging its own business was a good way to improve the information flow. It had been struggling to get confirmation that its suppliers were registering non-active, coformulant ingredients for the 2018 REACH deadline.
The compliance team raised the problem by highlighting that, if the ingredients were not registered, products could not be sold and that would cost much the same as the total value of its agchem sales in Europe. This sparked the attention of the CEO, who from the top ensured that solutions were found and executed. For the business, this meant going beyond one-way communication from customer to supplier.
The business itself sent emails to suppliers and then chased them up with telephone calls; the procurement department was trained in the regulation, so they could talk to suppliers and explain the needs. They discovered that one common reason that their emails went unanswered was because the recipient had no idea what they were about. The approach was successful. Key to its success was the connection between regulatory compliance and the business.
For some article makers, the different approaches companies have taken have resulted in a complex web of information requirements for suppliers. This has highlighted the need for a harmonised system that shares information on which chemicals are in finished products.
Industry and the authorities are now taking action to address this. Representatives from several sectors have come together to discuss how to develop a solution for collecting and sharing material data for articles – including their chemical composition – across sectors.
Meanwhile, the EU’s Council of Ministers has called on the European Commission and Echa to implement measures to ensure that by 2030 substances of concern in materials – including those in imported articles – can be traced through the entire supply chain.
Ensure you’re fully up to date with your business’ obligations under REACH
This article is an extract from our new report, The Impact of REACH on downstream users. Download your free copy to find out what downstream users of chemicals need to do to remain compliant with REACH.