In addition to registration, you should also be concerned about the development direction of REACH after 2018. With the development of EU REACH after 2018, the European Chemicals Agency (ECHA) will require operators to maintain registration updates, and will continue to conduct substance assessment and inquiry, authorization and restriction, and implement CLP Audit work such as specifications and safety data sheets. As a finished product supplier, you may be faced with finished product registration, notification or supply chain communication obligations. In July 2013, REACH enforcement agencies (including Belgium, Denmark, France, Germany, Norway, and Sweden) announced the compliance guidelines for substances of high concern in finished products (Guidance for Suppliers of Articles). In terms of supply chain communication, it is recommended that if the finished product contains SVHC > 0.1% (w/w), the industry should provide consistent information whether it is a separately sold finished product or an assembled finished product. And if the assembled finished product contains SVHC, the information content should include where the SVHC substance is contained, and the information should be communicated concisely among the supply chain. It is worth noting that on September 10, 2015, the European Court of Justice ruled that individual finished parts should be used as the basis for calculating SVHC 0.1% (W/W). Taking shirts as an example, the SVHC content of the shirt's textile fabric, buttons, and sewing threads will be calculated separately, instead of using a single shirt as the calculation unit. In order to comply with the requirements for information communication between REACH supply chains, it is recommended that companies analyze the information provided by suppliers and grasp the following principles to help focus on finished products that may contain SVHC: 1. When initially assessing that finished products or finished parts contain substances of high concern, Industry players can use raw materials as a starting point; 2. Further assess what substances of high concern those raw materials may contain.例如塑膠製的腳踏車把手握把套，其中的塑料可能會含有軟化劑； 3. 循序漸進地與處理複雜成品的供應商合作溝通，除了有助於資訊傳遞，或透過分析測試，驗證所蒐集到的information. In addition, seeking mutual cooperation among industries will not only find out which SVHC substances may be contained, but also accelerate the progress of REACH information transmission. It is very important to use tools and routines to confirm the transmission of REACH information, such as material confirmation lists during product development, using standardized forms during procurement, signing agreements and contracts with customers, requiring customers to provide third-party verification, product test reports, and conducting supplier audits. wait. As more and more SVHC substances are added to the candidate list, this procedure will enable manufacturers to effectively manage complex substance information, which will benefit suppliers who handle complex finished products. In addition, the industry should establish a quality management system to promote the implementation of REACH information transmission obligations and continue to add SVHC substances, because the responsibility to notify downstream customers takes effect immediately after the substance is added to the list, and the industry should complete the report to the European Chemical Agency within the next 6 months. Notify and respond to SVHC information within 45 days of general consumer requests. Denmark, Sweden, and Germany have all released mobile apps to provide general consumers with safety information requirements for the industry regarding SVHC in products. It is hoped that this will speed up the implementation of the EU REACH regulations and standardize communication in the finished product supply chain. The Industrial Bureau of the Ministry of Economic Affairs reminds my country's manufacturers exporting to Europe to actively develop corresponding strategies to protect business interests. For detailed definitions of finished products and case guidance, please refer to the attachment: Guidance for suppliers of articles_en.pdf
