November 15, 2011
Express Systems & Peripherals
623 Herman Road
Jackson NJ USA
REACH Ė ESP Incís Position
ESP Inc, being a distributor of electronic equipment, has a limited role in these new REACH regulations. Although electronic equipment can be characterized as articles and substances, ESP Inc is not considered a manufacturer, importer, downstream user, or registrant under Article 3 of REACH. ESP Inc. has no responsibility to register any of the components or equipment we distribute.
ESP Inc. does have the responsibility to communicate SVHC information down the supply chain when provided by the manufacturer, per article 33 of the directive.
ESP Inc. expects manufacturers to have robust environmental programs that adhere to the requirements of REACH, identify SVHC to ESP Inc., and provide ESP Inc. with a Safety Data Sheet or other document prescribing the safe handling of their products which contains SVHCs in excess of 0.1% in any of the products homogenous materials. This is not always the case as manufacturers are free to comply or not comply with environmental laws from other countries. Customers wishing to ensure purchased products are free of SVHCs should choose manufacturers that openly and publicly support REACH.
ESP Inc. has made suppliers aware of our above expectations and has asked for web links to their support and commitment to comply with REACH. ESP Inc. has posted these links to the manufacturer's page on our website.
When ESP Inc. is made aware of the presences of SVHC, we will communicate this to our customers, and provide them with a Safety Datasheet as required by article 33 of REACH. Safety Datasheets are meant to instruct the end-user (customer) on safe handling of the product with the SVHC. In most cases the amount will be small and encapsulated in the component. Exposure to the SVHC would require grinding the component up. This is not a normal way of handling the product, and a safety datasheet should reflect this distinction.
From ESP Inc's perspective, REACH is similar to RoHS. ESP Inc. globally distributes a very wide selection of products and suppliers. As with RoHS, not all the products we sell will be REACH compliant at one time. For this reason ESP Inc, cannot sign a global agreement on REACH Compliance. Customers must take an active role in understanding environmental compliance of product and selecting products accordingly.Please feel free to contact me with any questions.
Senior Vice President