REACH SVHC's 2012 - Assent Compliance
 

REACH SVHC's 2012 - Assent Compliance

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REACH SVHC's - What's Coming in 2012 was hosted by www.assentcompliance.com on May 9th. For information contact info@assentcompliance.com

REACH SVHC's - What's Coming in 2012 was hosted by www.assentcompliance.com on May 9th. For information contact info@assentcompliance.com

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REACH SVHC's 2012 - Assent Compliance REACH SVHC's 2012 - Assent Compliance Presentation Transcript

  • AS SENTCOM PLIANCEinfo@assenTcompliance.com w w w. a s s e n T c o m p l i a n c e . c o m Tel: 613.290.8044 REACH – Upcoming SVHCs – What is coming? Assent Compliance Krystal Noseworthy-Baker phone: 613.882.1429 krystal.baker@assentcompliance.comC u s t o m s o l u t i o n s f o r c o m p l i a n c e [ REAC H | R o H S | CP s i a | RSL | p r o p 6 5 ]
  • AS SENTCOM PLIANCE info@assenTcompliance.com w w w. a s s e n T c o m p l i a n c e . c o m Tel: 613.290.8044 Introduction to Assent Compliance Assent Compliance • Consulting • Global Requirements • Compliance Strategies • Regulatory Interpretations and Impacts • IT • Cloud Computing • Application Design • Operations • Program Implementation • Data Management C u s t o m s o l u t i o n s f o r c o m p l i a n c y [ REAC H | R o H S | CP s i a | RSL | p r o p 6 5 ]
  • AS SENTCOM PLIANCE info@assenTcompliance.com w w w. a s s e n T c o m p l i a n c e . c o m Tel: 613.290.8044 Agenda • Proposals for the SVHC Candidate List • Registry of Intentions – SVHC Candidate List • Industries affected by the possible SVHCs • Requirements for SVHCs • Consulting Services • Software Services • Q&A C u s t o m s o l u t i o n s f o r c o m p l i a n c y [ REAC H | R o H S | CP s i a | RSL | p r o p 6 5 ] View slide
  • AS SENTCOM PLIANCE info@assenTcompliance.com w w w. a s s e n T c o m p l i a n c e . c o m Tel: 613.290.8044 SVHC Candidate List Proposals 13 Proposed Deadline for commenting was April 12th, 2012 • Last Round of SVHCs: • Comment period ended October 13th, 2011. • SVHCs were published December 19th, 2011 EC CAS Substance Uses/materials Number Number • Inert solvent for grignard-, reduction- and alkylation-reactions. • Part of absorbing liquids in the industrial cleaning of gases (gas scrubber) 1,2-bis(2-methoxyethoxy)ethane 203-977-3 112-49-2 • Possibly be used as a catalyst for certain phase –transfer reactions (TEGDME; triglyme) • Also reported to be used in the formulation of electrolyte systems for lithium batteries • Reported to be used in Brake fluids. C u s t o m s o l u t i o n s f o r c o m p l i a n c E [ REAC H | R o H S | CP s i a | RSL | p r o p 6 5 ] View slide
  • AS SENTCOM PLIANCEinfo@assenTcompliance.com w w w. a s s e n T c o m p l i a n c e . c o m Tel: 613.290.8044 • Also useful as an inert solvent for organo metallic reactions • in general, e.g reactions involving alkali metals such as lithium, sodium and potassium, Pd • catalyzed couplings (Suzuki reaction), • Also used as solvent a for electrolytes of lithium batteries and as a process solvent for the recycling of Li-batteries1,2-dimethoxyethane; ethylene • Used in a process for the surface treatment of aluminium in 203-794-9 110-71-4 order to ensure surfaces are less reactiveglycol dimethyl ether (EGDME) • Likewise as an industrial reaction solvent, it facilitates certain reactions • including use as a solvent to facilitate formation of alkali met- al-hydrocarbon adducts and it is used in the Reformatsky reac- tion with methyl gamma-bromocrotonate • Also used as cleaning solvent and within solder fluxes within the microelectronics industry.C u s t o m s o l u t i o n s f o r c o m p l i a n c E [ REAC H | R o H S | CP s i a | RSL | p r o p 6 5 ]
  • AS SENTCOM PLIANCEinfo@assenTcompliance.com w w w. a s s e n T c o m p l i a n c e . c o m Tel: 613.290.8044 • EU Uses: Formulation and production of writing inks. • Solvent Violet 8 is used in inks and dyes • Dyeing a variety of materials, list includes: paper (copying, carbon), packaging, distemper, wood, lacquers, plastics, and feathers; while chemical catalogues refer additionally to uses in leather , as well • as in candle and rubber; there are also references to use in black dyes for polyacrylonitrile materials. Furthermore, according to the Colour Index potential uses include also dyeing of oil and fat products, as well as soaps. 4,4’-bis(dimethylamino)-4’’- 209-218-2 561-41-1 • The products (dyestuff) containing Solvent Violet 8 could (methylamino)trityl alcohol* have a diluent, but it would have to be soluble in solvents that are used to dissolve the dye. The commercial products listed can be supplied as powders or as pastes used for ballpoint pens, coatings on carbon paper, spirit inks, etc. (personal communi- cation with Society of Dyers and Colourists). • At the website of an Indian company Solvent Violet 8 is re- ported to being extensively used in fertilizers. • Finally, the literature refers to uses of Solvent Violet 8 in di- agnostic, analytical, and R&D applications, such as biological stain, while in chemical catalogues it is also reported to be used as anti-allergen and bactericide.* Note:Uses in literature: Although some companies that submitted classification and labelling notifications indicated “Solvent Violet 8” as a synonym of thesubstance 4,4’-bis(dimethylamino)-4’’- (methylamino)trityl alcohol), the Colour Index International identifies Solvent Violet 8 with EC and CAS numberswhich do not match the numerical identifiers of the substance 4,4’- bis(dimethylamino)-4’’-(methylamino)trityl alcohol). The information on potentialuses/applications refers to Solvent Violet 8 and the products containing, as it is cited by public on-line sources.C u s t o m s o l u t i o n s f o r c o m p l i a n c E [ REAC H | R o H S | CP s i a | RSL | p r o p 6 5 ]
  • AS SENTCOM PLIANCEinfo@assenTcompliance.com w w w. a s s e n T c o m p l i a n c e . c o m Tel: 613.290.8044 • Michler’s ketone is an important intermediate in the manufacture of triphenylmethane dyes. • The following is an indicative list of substances that are reported to be manufactured from Michler’s ketone: • C.I. Acid Blue 34; C.I. Acid Blue 86;C.I. Acid Blue 88; C.I. Acid Violet 15; C.I. Acid Violet 38; Acid Violet 2B; C.I. Basic Orange 23; C.I. Basic Violet 3; C.I. Basic Yellow 2; Ceres Blue I; Fanal Blue 3B supra; C.I. Solvent Violet 9; C.I. Solvent Yellow 34; Basazol Violet, Basic Brown C2, C.I. Basic Purple 48; Methyl Violet DAW; C.I. Basic Blue 26 (Gessner and Mayer, 2000). • References exist also on the use as an intermediate in the manufac- ture of pharmaceuticals as well as on applications in the produc- tion of polymers Michler’s ketone is also used as additive in dyes and pigments, acting as photosensitizer4,4-bis(dimethylamino) 202-027-5 90-94-8 • Used in photoinitiation systemsbenzophenone (Michler’s ketone) • Used as curing agent in ultraviolet (UV)-cured printing inks for cartonboard, acting as a catalyst to harden ink when it is exposed to UV light during the printing process • In the literature there are further reports on the use of Michler’s ketone as light absorbent, as well as in photoresist formulations • Also mentioned to be used as a component in dry film products and as a process chemical for electronic circuit board manufacture • Some analytical applications are listed as well • Used in repackaging and in Research & Development. • Colouring agent in the manufacture / production of paper and paper products. As mentioned above, it cannot be excluded that Michler’s ketone is rather present as impurity in other substance(s) used as colouring agents.C u s t o m s o l u t i o n s f o r c o m p l i a n c E [ REAC H | R o H S | CP s i a | RSL | p r o p 6 5 ]
  • AS SENTCOM PLIANCEinfo@assenTcompliance.com w w w. a s s e n T c o m p l i a n c e . c o m Tel: 613.290.8044 The main uses are: • Dye in ink applied in cartridges for printers and in ball pens and as dyestuff for paper colouring.[4-[4,4-bis(dimethylamino) • Minor dyestuff uses include carbon papers (where dyestuff is sus-benzhydrylidene]cyclohexa-2, pended in wax and applied to a thin impregnated paper), staining 208-953-6 548-62-9 of dried flowers/plants (dried plants dyed by immersion in a hot5-dien-1-ylidene]dimethylammo- water solution of the dyestuff) and as a marker (i.e. where dyestuffnium chloride (C.I. Basic Violet 3) is used to improve the visibility of a liquid). • Also used in microbial and clinical laboratories (e.g. as stain to dis- tinguish gram negative from gram positive bacteria) in presumably thousands of laboratories and teaching institutions around Europe. • Basic Blue 26 is used in inks, dyes, paints, and pigments. • Furthermore, Basic Blue 26 or its products are used for dyeing a variety of materials, such as paper, distemper, wood, and fibres/ textiles. • The commercial product (dyestuff) containing C.I. Basic Blue 26 may be a pure powder, a powder with diluents, or a solution with or without diluents.[4-[[4-anilino-1-naphthyl] • Uses relating to cosmetic products including hair products, cray-[4-(dimethylamino)phenyl]methy- ons, and soaps.lene]cyclohexa-2,5-dien-1-ylidene] 219-943-6 2580-56-5 • Finally, the literature refers to uses of Basic Blue 26 in diagnostic, analytical, and R&D applications, such as biological stain.dimethylammonium chloride (C.I.Basic Blue 26) • Production of various inks • Cleaners • Coating applications • Dyeing of various paper and plastic products (e.g. paper towel wipes , low grade paper and paper food trays, and other products) • Dyeing or painting of other articles • Ink in printing industryC u s t o m s o l u t i o n s f o r c o m p l i a n c E [ REAC H | R o H S | CP s i a | RSL | p r o p 6 5 ]
  • AS SENTCOM PLIANCEinfo@assenTcompliance.com w w w. a s s e n T c o m p l i a n c e . c o m Tel: 613.290.8044 • Glass Production (Borosilicate and crystal glass) • Glass fibre production • Frits production • Refractories • Use of Borates in Metallurgy • Flame Retardants • Nuclear applications • catalysts • Use of Borates polymer production • Intermediate use in the production of non-oxide ceramic powdersDiboron trioxide 215-125-8 1303-86-2 • Use of Borates in detergents and cleaners • Use of Borates in Industrial Fluids • INKS/PAINTS • Production of monocrystalline gallium arsenide wafers • Reagent chemicals • Agriculture • Construction materials • Adhesives • Crystal growth • Use of substance for productionC u s t o m s o l u t i o n s f o r c o m p l i a n c E [ REAC H | R o H S | CP s i a | RSL | p r o p 6 5 ]
  • AS SENTCOM PLIANCEinfo@assenTcompliance.com w w w. a s s e n T c o m p l i a n c e . c o m Tel: 613.290.8044 • Not registered for consumer use. • BUT measured in wooden toys and foam puzzle mats as well as in fitness and exercise mats which are made of ethylene vinyl acetate (EVA). • Not possible to characterise the origin for its presence in foam puzzle mats - Assumed that formamide is associated with a blow- ing agent used in the creation of foam and other consumer prod-Formamide 200-842-0 75-12-7 ucts, particularly those produced from EVA foam, that contain formamide, too. • Foam toys were also found to contain formamide. • Formamide is used as a solvent and plasticizer in consumer prod- ucts. It can be an ingredient as softener for paper, animal glues (which is mainly used for gluing wood), water soluble glues and wood stains • Solutions of lead(II) bis(methanesulfonate) are used in platingLead(II) bis(methanesulfonate) 401-750-5 17570-76-2 (both electrolytic and electroless). • These products are used in tin-lead plating.C u s t o m s o l u t i o n s f o r c o m p l i a n c E [ REAC H | R o H S | CP s i a | RSL | p r o p 6 5 ]
  • AS SENTCOM PLIANCEinfo@assenTcompliance.com w w w. a s s e n T c o m p l i a n c e . c o m Tel: 613.290.8044 • Used as a chemical intermediate in the manufacture of dyes and pigments, including Methylene red, C.I. Basic Yellow 2, Basic Orange 14, Solvent Orange 15, and Solvent Yellow 34 • Also used as chemical intermediate in the manufacture of its hy-N,N,N,N-tetramethyl-4,4- drochloric salt. The latter is used as an analytical reagent for the 202-959-2 101-61-1 determination of lead.methylenedianiline (Michler’s base) • Chemical reagent in Research & Development. • Use as a colouring agent in production of paper and paper products. • As mentioned above, it cannot be excluded that Michler’s base is pres- ent as impurity in substance(s) included in the imported mixtures. • TGIC is an epoxy compound that is used as a hardener in resins and coatings. • Main use is in polyester powder coatings for metal finishing and such coatings typically contain between 4 and 10% TGIC. • In Europe - used in weather-resistant powder coatings since the 1970s for coating articles such as steel garden furniture, car parts, metal fencing, window and door frames.TGIC (1,3,5-tris(oxiranylmethyl)- • Also used for powder coating electrical equipment, refrigerators, washing machines and ovens.1,3,5-triazine-2,4,6(1H,3H,5H)- 219-514-3 2451-62-9trione) • May also be used in inks in the printed circuit board industry, for example two-part inks used for solder-masking can contain up to around 60% TGIC in the hardener component. • Other uses reported include in electrical insulation materials, resin moulding systems, laminated sheeting, silk-screen printing coat- ings, tools, adhesives, lining materials and stabilisers for plastics. The technical grade substance is supplied under the trades names TEPIC, • Araldite PT 810 or TK 10622.C u s t o m s o l u t i o n s f o r c o m p l i a n c E [ REAC H | R o H S | CP s i a | RSL | p r o p 6 5 ]
  • AS SENTCOM PLIANCEinfo@assenTcompliance.com w w w. a s s e n T c o m p l i a n c e . c o m Tel: 613.290.8044 • Used in inks and dyes. • Solvent Blue 4 or its products are used for dyeing a variety of mate- rials, such as paper (e.g. carbon paper), distemper, wood, lacquers, feathers, and plastic. • May also be used in fuel .α,α-Bis[4-(dimethylamino)phenyl]-4 • Also reported to being extensively used in fertilizers.(phenylamino)naphthalene-1-meth- 229-851-8 6786-83-0 • Uses relating to cosmetic products are also listed (eg.soaps)anol (C.I. Solvent Blue 4) • Finally, the literature refers to uses in diagnostic, analytical, and R&D applications, such as biological stain. • Production of various inks, e.g. for printing (inks in publication gravure printers) or writing • Dyeing of paper • Use in mixtures such as windscreen washing agentsC u s t o m s o l u t i o n s f o r c o m p l i a n c E [ REAC H | R o H S | CP s i a | RSL | p r o p 6 5 ]
  • AS SENTCOM PLIANCEinfo@assenTcompliance.com w w w. a s s e n T c o m p l i a n c e . c o m Tel: 613.290.8044 • TGIC is an epoxy compound that is used as a hardener in resins and coatings. • Main use is in polyester powder coatings for metal finishing • Such coatings typically contain between 4 and 10% TGIC. • In Europe - used in weather-resistant powder coatings since the 1970s for coating articles such as steel garden furniture, car parts, metal fencing, window and door frames.β-TGIC (1,3,5-tris[(2S and 2R)-2,3- • Also used for powder coating electrical equipment, refrigerators,epoxypropyl]-1,3,5-triazine-2,4,6- 423-400-0 59653-74-6 washing machines and ovens.(1H,3H,5H)-trione) • May also be used in inks in the printed circuit board industry, for example two-part inks used for solder-masking can contain up to around 60% TGIC in the hardener component. • Other uses reported include in electrical insulation materials, resin moulding systems, laminated sheeting, silk-screen printing coat- ings, tools, adhesives, lining materials and stabilisers for plastics. The technical grade substance is supplied under the trades names TEPIC, Araldite PT 810 or TK 10622.C u s t o m s o l u t i o n s f o r c o m p l i a n c E [ REAC H | R o H S | CP s i a | RSL | p r o p 6 5 ]
  • AS SENTCOM PLIANCE info@assenTcompliance.com w w w. a s s e n T c o m p l i a n c e . c o m Tel: 613.290.8044 SVHC Candidate List Registry of Intentions 9 Registered • 5 have been on the list since 2008 and have no expected date of submission Expected Notification Substance name EC no. CAS no. date of Uses of intention submission • Man-made fluorosurfactant and global pollutant. • Perfluorooctanesulfonic acid is usually used as the sodium or potassium salts. • PFOS was the key ingredient in Scotchgard, a fabric protector made by 3M, and numerous stain repellents. • PFOS, together with PFOA, has also been used to make aque- ous film forming foam (AFFF), a component of fire-fighting foams, and alcohol-type concentrate foams. • PFOS compounds can be also found in some impregnation Perfluorooctanic acid agents for textiles, paper, and leather; in wax, polishes, paints, 206-397-9 335-67-1 16112011 28012013 (PFOA) varnishes, and cleaning products for general use; in metal sur- faces, and carpets. • In the semiconductor industry, PFOS is used in multiple photolithographic chemicals including: photoacid generators (PAGs) and anti-reflective coatings (ARCs). It has been phased out in the European Union semiconductor industry due to health concerns. • In Skydrol, a hydraulic fluid used in commercial aviation. • The most important emission sources of PFOS are metal plat- ing and fire-fighting foams. C u s t o m s o l u t i o n s f o r c o m p l i a n c E [ REAC H | R o H S | CP s i a | RSL | p r o p 6 5 ]
  • AS SENTCOM PLIANCEinfo@assenTcompliance.com w w w. a s s e n T c o m p l i a n c e . c o m Tel: 613.290.8044 • Derivative of PFAO • A surfactant used primarily as an aid in processing various fluoropolymers. • Ammonium perfluorooctanoate–also called APFO, PFOA, or C8–is a surfactant associated with the production of Teflon®. • It has been used in thousands of applications over the past 50 years. Some of these applications include its use in fire-fighting foams and as an inert ingredient in pesticides. • APFO may also be formed from the microbial degradation ofAmmoniumpentade- grease-resistant coatings applied to items such as pizza boxes 223-320-4 3825-26-1 16112011 28012013cafluorootanoate (APFO) (Fluoridealert) • This microbial degradation is suspected as the reason higher levels of APFO have been recorded in wastewater effluents than influents. • One of the chemicals known to breakdown into APFO is Zonyl® (Gruenberg, 2005). Zonyl® is used widely in the paper industry in items such as linerboard, folding cartons, bags, fast food wrappers, trays, and pet food liners. Zonyl® is also the chemical used in Stainmaster® carpets and fabrics. All ofthese products have the potential to break down into APFO and cause problems at wastewater treatment facilities.C u s t o m s o l u t i o n s f o r c o m p l i a n c E [ REAC H | R o H S | CP s i a | RSL | p r o p 6 5 ]
  • AS SENTCOM PLIANCEinfo@assenTcompliance.com w w w. a s s e n T c o m p l i a n c e . c o m Tel: 613.290.8044 • Phthalates are one of the most produced chemical groups with an annual production of several million tonnes per year. Phthalates are used as plasticisers (softeners) in plastics and PVC products, and also as solvents and fragrance carriers inDiisopentylphthalate 210-088-4 605-50-5 19042011 30072012 personal care products and cosmetics. • The use of phthalates has increased dramatically during the last 50 years and they are now found virtually everywhere in all kinds of products. Among many other items, phthalates can be found in carpets, flooring, toys, clothes, wallpapers, water pipes, paints, furniture, perfumes, cosmetics, cables and electronics. • Phthalates are not chemically bound to plastic materials so they can easily migrate into air, water, dust and humans. Therefore, exposure to phthalates is inevitable both for humans and for the environment.Di-n-pentyl phthalate 205-017-9 131-18-0 9112011 30012013 • The use of phthalates has increased dramatically during the last 50 years and they are now found virtually everywhere in all kinds of products. Among many other items, phthalates can be found in carpets, flooring, toys, clothes, wallpapers, water pipes, paints, furniture, perfumes, cosmetics, cables and electronics.Distillates (coal tar), heavy oils 292-607-4 90640-86-1 27062008 • The destructive distillation of bituminous coal produces ‘coal tar pitch’ a Volatile organic compound (CTPV) which containsDistillates (coal tar), heavy a wide variety of polycyclic aromatic hydrocarbons (PAH’s). 295-304-5 91995-42-5 27062008oils, pyrene fraction • PAHs occur in oil, coal, and tar deposits, and are produced as byproducts of fuel burning (whether fossil fuel or biomass).Distillates (coal tar), pitch, 295-313-4 91995-52-7 27062008pyrene fractionC u s t o m s o l u t i o n s f o r c o m p l i a n c E [ REAC H | R o H S | CP s i a | RSL | p r o p 6 5 ]
  • AS SENTCOM PLIANCEinfo@assenTcompliance.com w w w. a s s e n T c o m p l i a n c e . c o m Tel: 613.290.8044Residues (coal tar), pitch distn. 295-507-9 92061-94-4 27062008 • Pure inorganic arsenic is a gray-colored metal, but inorganic arsenic is usually found combined with other elements such as oxygen, chlorine, and sulfur • Arsenic combined with elements such as oxygen, chlorine, and sulfur forms inorganic arsenic; inorganic arsenic compounds include arsenic pentoxide, arsenic trioxide, and arsenic acid. Arsenic combined with carbon and hydrogen forms organic arsenic; organic arsenic compounds include arsanilic acid, ar-Further Arsenic compounds - - 30042008 senobetaine, and dimethylarsinic acid. • The major use for inorganic arsenic is in wood preservation; arsine is used in the microelectronics industry and in semicon- ductor manufacture. • Until the 1940s, inorganic arsenic solutions were widely used in the treatment of various diseases, such as syphillis and pso- riasis. Inorganic arsenic is still used as an antiparasitic agent in veterinary medicine and in homeopathic and folk remedies in the United States and other countries.C u s t o m s o l u t i o n s f o r c o m p l i a n c E [ REAC H | R o H S | CP s i a | RSL | p r o p 6 5 ]
  • AS SENTCOM PLIANCE info@assenTcompliance.com w w w. a s s e n T c o m p l i a n c e . c o m Tel: 613.290.8044 Industries Affected Most Common Uses for the proposed SVHCs TEGDME (triglyme) EGDME • Battery Industry • Automotive Industry (Brake fluids) • Cleaning Industry (cleaning solvents) • Microelectronics Industry (solders) • Printing Industry C u s t o m s o l u t i o n s f o r c o m p l i a n c E [ REAC H | R o H S | CP s i a | RSL | p r o p 6 5 ]
  • AS SENTCOM PLIANCE info@assenTcompliance.com w w w. a s s e n T c o m p l i a n c e . c o m Tel: 613.290.8044 Industries Affected (Continued) Most Common Uses for the proposed SVHCs Diboron Trioxide • Glass industry • Production (Borosilicate and crystal glass) • Glass fibre production • Frits production • Refractories • Metallurgy • Flame retardants • Nuclear applications • Polymer Industry • Detergent and Cleaners Industry • Inks and Paints Industries • Semi-Conductor Industry (Production of monocrystalline gallium arsenide wafers) • Reagents and Catalysts • Agriculture • Construction materials • Adhesives – Multi-Industry Impact C u s t o m s o l u t i o n s f o r c o m p l i a n c E [ REAC H | R o H S | CP s i a | RSL | p r o p 6 5 ]
  • AS SENTCOM PLIANCE info@assenTcompliance.com w w w. a s s e n T c o m p l i a n c e . c o m Tel: 613.290.8044 Industries Affected (Continued) Most Common Uses for the proposed SVHCs FORMAMIDE • Toy and consumer industry (wooden toys, foam toys, foam puzzle mats, solvent and plasticizer in consumer products) • Glue manufacturers • Wood article manufacturers (animal glues and wood stains) Lead(II) bis(methanesulfonate) • Electronics Industry (tin-lead plating) TGIC β-TGIC Both epoxy compounds used as a hardener in resins and coatings • Automotive industry • Silk Screen Printing • Fencing, Window and Door Manufacturers • Adhesives Industry • Electronics Industry • Printed Circuit Board (PCB) industry (inks) • Appliances Industry • Plastics Industry (stabilizer) C u s t o m s o l u t i o n s f o r c o m p l i a n c E [ REAC H | R o H S | CP s i a | RSL | p r o p 6 5 ]
  • AS SENTCOM PLIANCE info@assenTcompliance.com w w w. a s s e n T c o m p l i a n c e . c o m Tel: 613.290.8044 Industries Affected (Continued) Most Common Uses for the proposed SVHCs CI Basic Violet 3 / CI Basic Blue 26 / CI Solvent Blue 4 4,4’-bis(dimethylamino)-4’’-(methylamino)trityl alcohol • Inks, Dyes, Paints, Pigments Industry • paper and paper products • packaging • wood • fibres and textiles • Analytical reagent and R&D applications • possible cosmetic use • cleaners, coating application dyes in wood, lacquers, plastics, leathers • fuel • fertilizers C u s t o m s o l u t i o n s f o r c o m p l i a n c E [ REAC H | R o H S | CP s i a | RSL | p r o p 6 5 ]
  • AS SENTCOM PLIANCEinfo@assenTcompliance.com w w w. a s s e n T c o m p l i a n c e . c o m Tel: 613.290.8044Industries Affected (Continued)Most Common Uses for the proposed SVHCsMichler’s ketone / Michler’s base• Dyes and Pigments Industry • colouring agent in paper and paper products• Pharmaceuticals• Polymer production• Analytical reagent and R&D applicationsC u s t o m s o l u t i o n s f o r c o m p l i a n c E [ REAC H | R o H S | CP s i a | RSL | p r o p 6 5 ]
  • AS SENTCOM PLIANCE info@assenTcompliance.com w w w. a s s e n T c o m p l i a n c e . c o m Tel: 613.290.8044 Industries Affected Most Common Uses for the intended SVHCs PFOA • Previously fabric protection and stain repellents - key ingredient • Metal plating • Fire-fighting foams • Semiconductor Industry – phased out in the EU • Aviation industry (hydraulic fluid) • Consumer products (impregnation agent) • textiles, paper, and leather; in wax, polishes, paints, varnishes, and cleaning products for general use APFO • Formed from the microbial degradation of grease-resistant coatings applied to items such as pizza boxes • One of the chemicals known to breakdown into APFO is Zonyl® • Paper industry »» linerboard, folding cartons, bags, fast food wrappers, trays, and pet food liners. • Stainmaster® carpets and fabrics. C u s t o m s o l u t i o n s f o r c o m p l i a n c E [ REAC H | R o H S | CP s i a | RSL | p r o p 6 5 ]
  • AS SENTCOM PLIANCE info@assenTcompliance.com w w w. a s s e n T c o m p l i a n c e . c o m Tel: 613.290.8044 Industries Affected Most Common Uses for the intended SVHCs Diisopentylphthalate / Di-n-pentylphtalate • Multi-Industry Impact - Plasticizers • carpets, flooring, toys, clothes, wallpapers, water pipes, paints, furniture, perfumes, cos- metics, cables and electronics Further Arsenic Compounds • Furniture Industry (wood preservation) • Microelectronics Industry • Semiconductor Industry • Veterinary and homeopathic applications (antiparasitic agent) Coal Tar Distillates and Residues • Fuel, Oil Industries C u s t o m s o l u t i o n s f o r c o m p l i a n c E [ REAC H | R o H S | CP s i a | RSL | p r o p 6 5 ]
  • AS SENTCOM PLIANCE info@assenTcompliance.com w w w. a s s e n T c o m p l i a n c e . c o m Tel: 613.290.8044 SVHCs – MORE TO COME • Current Candidate List sits at 73 substances • A commitment to have 136 SVHCs by the end of 2012 was communicated in March 2010 by Janez Potocnik, EU Environmental Commissioner, and Antonio Tajani, EU Industry and Enterprise Commissioner. • This commitment was nonbinding and it has come to light that this is unattainable »» Various reasons including budgetary pressures and a closer review of the substances • The new target of the European Commission is to have 15 substances added to the candi- date list by the end of 2012. »» 13 substances are expected to be added in June, and a few others in August. »» This would bring the total number of SVHCs to at least 88 by the end of the year. C u s t o m s o l u t i o n s f o r c o m p l i a n c E [ REAC H | R o H S | CP s i a | RSL | p r o p 6 5 ]
  • AS SENTCOM PLIANCE info@assenTcompliance.com w w w. a s s e n T c o m p l i a n c e . c o m Tel: 613.290.8044 Requirements What do new SVHCs mean for your company? Companies will need to assess whether they have legal obligations resulting from the inclusion of the new substances in the Candidate List. The legal obligations related to SVHCs include Communication and Notification. Communication Any producers or importers of articles placed on the market1 in the EU must declare the presence of any of these substances in an article in a concentration exceeding 0.1% w/w. Article 33 – Source of compliance requirement: Duty to communicate information on substances in articles: 1. Any supplier of an article containing a substance meeting the criteria in Article 57 and identi- fied in accordance with Article 59(1) in a concentration above 0,1 % weight by weight (w/w) shall provide the recipient of the article with sufficient information, available to the supplier, to allow safe use of the article including, as a minimum, the name of that substance. 2. On request by a consumer any supplier of an article containing a substance meeting the cri- C u s t o m s o l u t i o n s f o r c o m p l i a n c E [ REAC H | R o H S | CP s i a | RSL | p r o p 6 5 ]
  • AS SENTCOM PLIANCEinfo@assenTcompliance.com w w w. a s s e n T c o m p l i a n c e . c o m Tel: 613.290.8044 teria in Article 57 and identified in accordance with Article 59(1) in a concentration above 0,1 % weight by weight (w/w) shall provide the consumer with sufficient information, avail- able to the supplier, to allow safe use of the article including, as a minimum, the name of that substance. The relevant information shall be provided, free of charge, within 45 days of receipt of the request.1 Article 3.12 of the REACH Regulation specifies: • Placing on the market: means supplying or making available, whether in return for payment or free of charge, to a third party. Import shall be deemed to be placing on the market;C u s t o m s o l u t i o n s f o r c o m p l i a n c E [ REAC H | R o H S | CP s i a | RSL | p r o p 6 5 ]
  • AS SENTCOM PLIANCE info@assenTcompliance.com w w w. a s s e n T c o m p l i a n c e . c o m Tel: 613.290.8044 Requirements What do new SVHCs mean for your company? • What does this mean? • Once a substance has been added to the SVHC List, you must declare its presence to your downstream users if the concentration is above 0.1% of your products weight. • This is to be done upon immediately for professional customers and within 45 days from request for consumers. C u s t o m s o l u t i o n s f o r c o m p l i a n c E [ REAC H | R o H S | CP s i a | RSL | p r o p 6 5 ]
  • AS SENTCOM PLIANCE info@assenTcompliance.com w w w. a s s e n T c o m p l i a n c e . c o m Tel: 613.290.8044 Requirements (Continued) What do new SVHCs mean for your company? Notification Furthermore, these same producers and importers have six months from the date the new SVHCs were included (19 June 2012) to notify the ECHA if (a) The (SVHC) is present in those articles in quantities totalling over 1 tonne per producer or importer per year (and) (b) The (SVHC) is present in those articles above a concentration of 0,1 % weight by weight (w/w) • A notification is created using the same software as a REACH registration – IUCLID. • It is a much less intense dossier than a registration dossier. • To facilitate the task of notification, ECHA has made available pre-filled substance datasets in IUCLID 5.3 format. • Each Candidate List substance has its own pre-filled dataset, which can be downloaded from the Candidate List webpage. • These datasets contain: »» The identity (substance name, EC and/or CAS number) »» The classification and labelling of the substance. C u s t o m s o l u t i o n s f o r c o m p l i a n c E [ REAC H | R o H S | CP s i a | RSL | p r o p 6 5 ]
  • AS SENTCOM PLIANCEinfo@assenTcompliance.com w w w. a s s e n T c o m p l i a n c e . c o m Tel: 613.290.8044 • The following information must be entered by the notifier: »» identity and contact details, »» registration number (if available), »» the tonnage range of the substance, »» a brief description of the uses of the substance in the article itself and the uses of the article. • REACH-IT is the submission tool that must be used.C u s t o m s o l u t i o n s f o r c o m p l i a n c E [ REAC H | R o H S | CP s i a | RSL | p r o p 6 5 ]
  • AS SENTCOM PLIANCE info@assenTcompliance.com w w w. a s s e n T c o m p l i a n c e . c o m Tel: 613.290.8044 Requirements (Continued) What do new SVHCs mean for your company? Authorisation Any chemicals placed on the Candidate List can also eventually be approved for an authorization list where they will then be banned from use unless an authorization is submitted and approved before the applicable sunset date. • Most, if not all, substances on the current SVHC List will eventually move onto the Authorisation list and therefore require an Authorisation for their use. • Authorisations are required on a per substance, per use, per supply chain (you or an actor up your supply chain must have been granted an authorisation) basis. C u s t o m s o l u t i o n s f o r c o m p l i a n c E [ REAC H | R o H S | CP s i a | RSL | p r o p 6 5 ]
  • AS SENTCOM PLIANCE info@assenTcompliance.com w w w. a s s e n T c o m p l i a n c e . c o m Tel: 613.290.8044 Requirements (Continued) What do new SVHCs mean for your company? Authorisation Process – Annex 15 Dossiers: 1. Registry of intentions – Intention to submit dossier • 9 Registered, 4 most recently 2. Submission of Annex XV dossier (SVHC Dossier) to ECHA for Compliance Check • 13 Proposed 3. Publication of Annex XV dossier (once it has passed compliance check) 4. After Commenting periods – Candidate List (Article 33 Requirements kick in) 5. Prioritisation list – Order in which substances will be reviewed for Authorisation 6. Authorisation List – Restrictions and Authorisations handed out C u s t o m s o l u t i o n s f o r c o m p l i a n c E [ REAC H | R o H S | CP s i a | RSL | p r o p 6 5 ]
  • AS SENTCOM PLIANCEinfo@assenTcompliance.com w w w. a s s e n T c o m p l i a n c e . c o m Tel: 613.290.8044An Authorisation will contain the following information:• Substance identity• Substance intrinsic properties of very high concern,• Sunset date, date by when a substance can no more be used without authorisation• Application date, date before which an application for authorisation for each use that is not exempted from the authorisation requirement must be made, in order to continue to use the substance for the specific use.• Review period for uses, if appropriate • Exempted uses or categories of usesC u s t o m s o l u t i o n s f o r c o m p l i a n c E [ REAC H | R o H S | CP s i a | RSL | p r o p 6 5 ]
  • AS SENTCOM PLIANCE info@assenTcompliance.com w w w. a s s e n T c o m p l i a n c e . c o m Tel: 613.290.8044 Requirements SVHC Declaration examples AMERICAN ZETTLER, INC. 75 COLUMBIA • ALISO VIEJO, CA 92656 • 949-831-5000 • FAX 949-831-8642 To: Supplier Reach Team From: Ed Edsinga Date: 10/27/2008 Release date 2/12/2010 Revised Not updated to the most recent SVHC list but the format 6/29/2010 Revised 2/14/2011 Revised 6/25/2011 Revised and necessary elements are otherwise present Subject: Reach Directive Supplier Communication of SVHC _ EU Regulation EC 1907/2006_AMERICAN ZETTLER INCORPORATED Reach Directive declaration: Valid for all American Zettler Inc. companies: American Zettler, Zettler Magnetics, Zettler Controls, and AZ Displays. American Zettler products supplied to customers do not contain any of the reported substances listed in the SVHC_EU Regulation EC 1907/2006 “list of substances” from October 28, 2008, added substances f rom January 13, 2010, June 18, 2010 & December 15, 2010. (Candidate List of Substances of very High Concern – total 53 substances). Zettler procures articles (not chemicals) which are not intended to release any substance under normal and reasonable foreseeable conditions of use. Signed: Ed Edsinga Engineering Manager www.azettler.com C u s t o m s o l u t i o n s f o r c o m p l i a n c E [ REAC H | R o H S | CP s i a | RSL | p r o p 6 5 ]
  • AS SENTCOM PLIANCEinfo@assenTcompliance.com w w w. a s s e n T c o m p l i a n c e . c o m Tel: 613.290.8044 Subject: European Union Regulation (EC) 1907/2006. Updated December 19, 2011. Registration, Evaluation, Authorization and Restriction of Chemicals. (REACH) ​ The subject directive undertakes the identification and definition of chemicals of concern, and preparation of said chemicals, that are contained in products for use in the European Union. It details registration obligations of manufactures and suppliers to assure compliance. The shape, surface and design of our products (articles) are paramount to the chemical composition. LYN-TRON products are deemed articles, as defined in the REACH Directive. Articles are exempt from REACH unless they release a SVHC (Substance of Very High Concern) as identified in the regulation. Lyn-Tron, Inc. does not manufacture or distribute any products that contain these substances. No chemicals or substances are intentionally released from Lyn-Tron’s products. Lyn-tron, Inc. products are Halogen free. For these reasons, Lyn-Tron products are considered articles that are not affected by the REACH Directive. They do not require registration. -- Paragraph 32 and Chapter 2 (3.3) Sincerely, Michael E. Quinn Exec Vice President ​ ​ ​ ​ ​ ​ ​ Lyn-Tron Reach Statement • Company Header • Appropriate individual • Date is current • Inaccurate understanding of REACH responsibilitiesC u s t o m s o l u t i o n s f o r c o m p l i a n c E [ REAC H | R o H S | CP s i a | RSL | p r o p 6 5 ]
  • AS SENTCOM PLIANCEinfo@assenTcompliance.com w w w. a s s e n T c o m p l i a n c e . c o m Tel: 613.290.8044 Momentive SVHC – RTV167 2012-01-16 • Company Header • Appropriate individual • Includes appropriate regulatory reference • Date is currentC u s t o m s o l u t i o n s f o r c o m p l i a n c E [ REAC H | R o H S | CP s i a | RSL | p r o p 6 5 ]
  • AS SENTCOM PLIANCE info@assenTcompliance.com w w w. a s s e n T c o m p l i a n c e . c o m Tel: 613.290.8044 How can Assent Help? Consulting Services • Manage the compliance to ROHS, REACH, CLP and other Environmental standards • Ensure compliance with regulatory agencies and compliance regulations • Review and evaluate environmental requirements and changes as published by regulating bodies • Support sourcing and selection of electronic and mechanical components • Serve as subject matter expert on regulatory matters • Specification and drawing review for compliance • Obsolescence management and part substitution • Work with suppliers on corrective actions C u s t o m s o l u t i o n s f o r c o m p l i a n c E [ REAC H | R o H S | CP s i a | RSL | p r o p 6 5 ]
  • AS SENTCOM PLIANCE info@assenTcompliance.com w w w. a s s e n T c o m p l i a n c e . c o m Tel: 613.290.8044 How can Assent Help? REACH Specifications P.O. Box 1980 Phone: 765.983.5200 Richmond, IN 47375-1980 Fax: 765.983.5257  Belden Supplier Environmental Specification ENV001 Rev. 2/10/10 This specification outlines the environmental requirements for all purchased materials to be used in cable products and all finished goods for the Belden Americas Division, Effective April 1, 2005. Belden Spec ENV001 • Insert appropriate regulatory reference for REACH – Regulation Belden Americas Division’s Policy is to comply with all known environmental regulations worldwide. We will endeavor to market and manufacture products that are compliant, rather than label or otherwise identify non- compliant products. Therefore, all materials and finished goods supplied to Belden Americas Division shall EC No 1907/2006 also comply with known environmental regulation, including but not limited to: - California Proposition 65 Consent Judgment for Wire & Cable Mfgs. (San Francisco Superior Court Nos. 31262 and 320342) - EU ROHS (Directive 2002/95/EC, 27-Jan-2003) - EU ELV (Directive 2000/53/EC, 18-Sept-2000) - Anthracene Oil • This is also outdated at this point, the chemical requirements - EU WEEE (Directive 2002/96/EC, 27-Jan-2003) - Diisobutyl Phthalate - Aluminosilicate - EU Brominated Flame Retardants (Directive 2003/11/EC, 6-Feb-2003) - Zirconia Aluminosilicate (based solely on the REACH SVHC list) is not current - China ROHS (Ministry of Information Industry OrderLead Chromate - #39 ) - Lead Chromate Molybdate Sulfate Red • Insert the link to the current SVHC Candidate List along with - EU REACH - Lead Sulfochromate Yellow - Acrylamide In addition to these regulations, Belden Americas Division (2-Chloroethyl Phosphate) use of the following - Tris has also restricted the wording ensuring the supplier is given the responsibility to stay - Coal Tar Pitch substances. These substances must not be present as intentionally added to any material for finished good (other than trace amounts). - Perflurooctanyl sulfonate (PFOS) - Bisphenol A (BPA) - Asbestos and its compounds - Cadmium and its compounds - Chromium VI and its compounds The following substances may be present, but their quantity by weight per homogeneous material must be reported to Belden Americas Division. aware and compliant to the most current list - Lead and its compounds - Mercury and its compounds - Other brominated flame retardants compounds - Antimony and its compounds - Polybrominated biphenyls (PBBs) and their ethers/oxides (PBDEs PBBEs) - Arsenic • Can continue to also list the SVHC Candidate List, this is added clarification to suppliers - Di-(2-ethylhexyl) phthalate (DEHP)[Dioctylphthalate Beryllium and its compounds - (DOP)] - Ethylene glycol ethers - Penta-,Octa-, and Deca- BDE compounds - Organic tin compounds - Organophosphate compounds - Antracene - Other phthalates • CAS Numbers should be included - Perflurooctanoic acid (PFOA) - 4,4’- Diaminodiphylmentane - Polyaromatic Hydrocarbons (PAH) - Dibutyl phthalate (DBP) - Cyclododecane Suppliers of materials and finished goods shall report to Belden Americas Division their compliance to the above requirements beginning with the first shipment on/after April 1, 2005 and with the first annual shipment - Cobalt dichloride • Trace amounts should be defined thereafter. In addition, notification shall be sent if a materials or finished good status changes for any reason. - Diarsenic pentaoxide The report shall be sent to: - Diarsenic trioxide - Belden Americas Division - Sodium dichromate, dehydrate ATTN: Purchasing- Materials Environmental Compliance Report • Advise to create and send-out a reporting tool to record the - 5-Tert-butyl-2,4,6-trinito-m-xylene 2200 US Hwy 27 South - Hexabromocyclododecane (HBCDD) Richmond, IN 47374-7279 - Alkanes, C10-13, Chloro(Short chain chlorinated paraffins) information requested - Bis (tributyltin)oxide - Lead hydrogen arsenate - Triethyl arsenate - Benzyl butyl phthalate (BBP) - 2,4-Dinitrotoluene • As a separate note, the RoHS recast (Directive 2011/65/EU) should be added to the list of regulations C u s t o m s o l u t i o n s f o r c o m p l i a n c E [ REAC H | R o H S | CP s i a | RSL | p r o p 6 5 ]
  • AS SENTCOM PLIANCE info@assenTcompliance.com w w w. a s s e n T c o m p l i a n c e . c o m Tel: 613.290.8044 How can Assent Help? Supply Chain Follow-Up Process FOLLOW UP process 30 days after supplier-provided resolution date, a call is placed to the Supplier by the Project Manager YES Update database. Has the Supplier Follow-Up process resolved the part? completed. NO New date is agreed upon between Project Manager and Supplier 30 days after second supplier-provided resolution date, a meeting is setup with the Supplier, the Project Manager and the Purchasing Manager. Supplier parts must be defined as either “Yes”, “No” or “Unknown” after this meeting as per the Supplier Survey Process and dealt with accordingly. C u s t o m s o l u t i o n s f o r c o m p l i a n c E [ REAC H | R o H S | CP s i a | RSL | p r o p 6 5 ]
  • AS SENTCOM PLIANCE info@assenTcompliance.com w w w. a s s e n T c o m p l i a n c e . c o m Tel: 613.290.8044 How can Assent Help? Creating Terms and Conditions Company X Terms and Conditions EU REACH/RoHS China RoHS Non-Company X brand (i.e., third-party/Supplier logo) products must comply with applicable legal requirements. This Specification communicates Company X’s requirements for Company X brand products and materials, parts and assemblies incorporated into Company X Brand products worldwide, in accordance with theRoHS requirements do not apply to spare requirementsrepair, or reuse, provide REACH-compliant safety data sheets, The European parts for the of electrical and electronic equipment put on the market beforeapplicable and Union directive for the Restriction of Hazardous Substances (RoHS), the as July 1, 2006, batteries or process chemicals. including requirements associated with the CLP Regulation2. European Union regulation Registration, Evaluation, Authorisation and Restriction of Chemicals (REACH) as well as China RoHS. The current candidate list of SVHC as published by the EU is located at: Table 1 – RoHS Substance Restrictions Substance Threshold http://echa.europa.eu/web/guest/candidate-list-table 1.0 Regulatory Requirements Company X brand products and materials, parts and assemblies in Level weight % (ppm) Additional information on Substances of Very High Concern under REACH can Company X brand electrical and electronic products must Cadmium(Cd)andits compounds meet the 0.01% (100 be found at: following requirements: ppm) http://echa.europa.eu/web/guest/addressing-chemicals-of- Hxvle Crmu ( r )a its c m o n s e a a nt ho i mC6 nd o p u d 0.1% (1000 concern/authorisation/substances-of-very-high-concern- 1. DIRECTIVE 2011/65/EU OF THE EUROPEAN PARLIAMENT AND OF THE identification/candidate-list-of-substances-of-very-high-concern-for- ppm) COUNCIL of 8 June 2011 on the restriction of the use of (Pb) and its compounds Lead certain authorisation 0.1% (1000 hazardous substances in electrical and electronic equipment (recast) ppm) (RoHS II)1; Additional information on REACH can be found at the European Chemicals Merc ( ga its c m o n s ury H) nd o p u d 0.1% (1000 2. REGULATION (EC) No 1907/2006 OF THE EUROPEAN PARLIAMENT Agency web site at: ppm) AND OF THE COUNCIL of 18 December 2006 concerningatethe (PBB) http://echa.europa.eu/web/guest/regulations/reach/understanding-reach Polybromin dbpi henyl 0.1% (1000 Registration, Evaluation, Authorisation and Restriction of Chemicals 4.0 Products for People’s Republic of China: Company X brand ppm) (REACH); products and parts and assemblies for “independent commercial sale” in Polybrominaeddiphe ether (B EincludingDcB E t nyl P D) , ea D 0.1% (1000 3. Administrative Measure on the Control of Pollution Caused by China must meet the requirements of “The Management Methods for ppm) Electronic Information Products (China RoHS) Controlling Pollution by Electronic Information Products (EIP)” (“China 4. All other applicable laws and regulations; RoHS”). Additional information on RoHS and RoHS II can be found at: Should the requirements of this Specification conflict with applicable http://www.bis.gov.uk/nmo/enforcement/rohs-home China RoHS includes the same restricted substances as EU RoHS, listed in governmental regulations or legislation the more stringent requirements Table 1.Company X suppliers are required to report the presence of the shall take precedence. The RoHS recast legislation, including exemptions, can be found at: in Table 1 at the homogeneous level in amounts restricted substances http://eur-lex.europa.eu/LexUriServ/LexUriServ.do? thresholds listed in Table 1. exceeding the 2.0 RoHS Requirements uri=OJ:L:2011:174:0088:0110:EN:PDF Homogeneous materials within new Company X brand products and parts English summary on China RoHS and China RoHS links (Chinese and English) and assemblies for new Company X brand products must 3.0 exceed the EU Very High Concern (SVHC) in Articles - Reporting not Substances of available at: RoHS substance restrictions in Table 1. Any applicable exemptions must be Requirements http://www.tradecommissioner.gc.ca/eng/document.jsp? duly communicated by the supplier. Under REACH, Company X products are defined as “articles”. did=73745&cid=512&oid=807 1 The recast RoHS Directive 2011/65/EU (RoHS II) hasArticle: means an object which during production is given a special shape, repealed Directive 2002/95/EC (RoHS). The recast RoHS Directivedesign which determines its function to a greater degree than surface or does its chemical composition; 2011/65/EU was published in the Official Journal of the European Union on 1 July 2011 and entered into force on 21 July 2011. 2 REGULATION (EC) No 1272/2008 OF THE EUROPEAN PARLIAMENT AND OF As such, Company X requires suppliers to identify (Substance name, CAS and/or EC number) if any Substances of Very High COUNCILof 16 December 2008 on classification, labelling and packaging THE Concern (SVHC) are of substances and mixtures, amending and repealing Directives 67/548/EEC present at or above the 0.1% weight by weight (w/w). Suppliers of substances and/or preparations are also required to meet REACH registration Regulation (EC) No 1907/2006 and 1999/45/EC, and amending http://eur-lex.europa.eu/LexUriServ/LexUriServ.do? uri=OJ:L:2008:353:0001:1355:en:PDF C u s t o m s o l u t i o n s f o r c o m p l i a n c E [ REAC H | R o H S | CP s i a | RSL | p r o p 6 5 ]
  • AS SENTCOM PLIANCE info@assenTcompliance.com w w w. a s s e n T c o m p l i a n c e . c o m Tel: 613.290.8044 How can Assent Help? Software Services • Automatically gather environmental compliance data from your supply chain (Declarations, COC’s, DOC’s, etc.) • Platform for suppliers to enter environmental compliance information • Generate custom reports based on gathered compliance data: • Allows for a top level view of compliance progress or a drill down to product or part level compliance • Instantly isolate problem areas based on products, parts or materials. • Generate compliance documents for Enforcement agencies and downstream users. • Acts as a platform for internal teams to manage environmental data and make internal declara- tions based on obtained information: • Engineering Override • Automatic communication tool to inform suppliers of changes to environmental regulations • Free model for large cap companies looking to implement a software platform with their supply chain C u s t o m s o l u t i o n s f o r c o m p l i a n c E [ REAC H | R o H S | CP s i a | RSL | p r o p 6 5 ]
  • AS SENTCOM PLIANCE info@assenTcompliance.com w w w. a s s e n T c o m p l i a n c e . c o m Tel: 613.290.8044 Questions? Please submit your questions in writing using the Q&A tool along the top menu tool bar. Any questions not addressed during the Q&A portion of this webinar will be addressed in private correspondence after the webinar. C u s t o m s o l u t i o n s f o r c o m p l i a n c E [ REAC H | R o H S | CP s i a | RSL | p r o p 6 5 ]