1. APPENDIX II REACH
INTERPRETATION GUIDELINES
Phased Declaration
Process
Recommendation for Phased Declaration of substances
used in articles within Aerospace and Defense industries
Version 1 – September 2008
CONCEPT DESIGN HCSGM 20080736 - SEPTEMBER 2008 - PRINTED IN FRANCE

2. Attention Authors
This document aims to provide a This document has been produced
general and simplified explanation by AeroSpace and Defence
of the mechanisms for a phased Industries Association of Europe
declaration of substances within the with the active participation of
Aerospace and Defense Industries, representatives of the various
in order to comply with the EU companies below:
REACH regulation.
It should not be used as a ASD REACH Working Group
substitute for the applicable rules as
they are described in regulation (CE) AIRBUS S.A.S
No 1907/2006 and other applicable
texts. ASD
The authors cannot be held BDLI
responsible for the consequences
of any extensive or inappropriate DASSAULT-AVIATION
use made of the content of this
document. GIFAS
The authors of this document have MEGGITT
based their interpretation on the
documents available at the time of ROLLS ROYCE
writing. Some of these references
may still be modified. SAAB
SAFRAN
THALES
REACH / Phased Declaration Process
REACH / Phased Declaration Process
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3. Preamble
Aerospace and Defence Industries have always been focussed on The DSL is NOT specific to the substances used within the aerospace and
material specifications and as a consequence the substances contained in defence sector. However, the PDSL is a subset of the Declarable Substance
their products. REACH, amongst other legislation, is accelerating Industry to List, based on a combination of both:
take more consideration of substances in products and how the relevant data
has to be collected and presented. • The hazards posed by the substances
• The substances posing the highest business risks to the aerospace
Tracking and collecting this data on substances will require many companies and defence value chain
to invest in IT systems to receive and store this information. As REACH and
the Globally Harmonized System (GHS) will lead to further changes of The PDSL is available to sector members, in particular via trade association
classification and labelling of substances, a systematic update of this infor- websites linked to ASD, and will also be available as a subset within the DSL
mation is required to anticipate substances that may become unavailable and when the second issue of the ASD-STAN Technical Reports 9535 and 9536
ensure appropriate sustainable technological choices. is issued.
The position described here is intended to progressively develop the level of A group of experts covering a wide range of expertise along the aerospace
substance declaration, while enabling the companies to develop their ability and defence value chain will be set up to maintain and edit the list of Priority
to manage the relevant information and the impact on their business. Declarable Substances (PDSL) and the list of Declarable Substances (DSL).
On the basis of new information being made available either on the use of
substances within the aerospace and defence sector or on the properties of
The ASD REACH Implementation Working Group, any substance, the original PDSL may require modification.
The PDSL will also evolve depending on future publications of ECHA and
1 having noted the REACH legal provisions (particularly the development of the Candidate List.
corresponding timeline and mechanisms) as laid out in Regulation
1907/2006 This proposal will be reviewed and amended as required by the REACH
2 having recognised the need to offer the supply chain a standardised Implementation Working Group of ASD, gathering lessons learnt from the
way of sharing information implementation.
3 having recognised the necessary development of IT systems and the
time required to deliver them
4 having recognised the necessity to address both business and
compliance risks simultaneously.
5 having recognised that the technological options for tomorrow’s
products are taken today, greater information should be made available
across the supply chain to ensure the continuous supply of
substances/articles for production and maintenance of long life cycle
products
has taken the following position:
ASD-STAN and SAE Technical Reports are issued as tools for the supply
chain. The first Technical Reports to be issued are:
• A list of Declarable Substances (DSL) ASD STAN TR 9536 or SAE
REACH / Phased Declaration Process
ARP9536
• A subset list of the Declarable Substances List (DSL) ASD STAN 9536
or SAE ARP9536 named: Priority Declarable Substances List (PDSL)
• A Material Declaration Form ASD STAN TR 9535 or SAE AS9535
These documents can be found at the following locations:
http://www.asd-europe.org/salesEngineStandardTR.asp
http://www.sae.org/technical/standards
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4. Phased Declaration Process
Recommendation Agenda of the different lists
for phased declaration to report on for the coming
for substances to be found years
in articles >0.1% by weight
1) Candidate list (official list of ECHA)
Number of substances
As soon as the candidate list is officially published (first issue to be identified in articles
expected in October 2008) it is recommended (as per article 33) for
the recipient of an article to contractually/legally request all EU and
non EU suppliers to notify whether or not substances from the Can-
didate List are to be found in the article (in a concentration above
0.1% weight by weight) Any EU supplier is legally obliged to provide
this information against Article 33 of the REACH legislation.
2) Priority declarable substances list (PDSL)
It is recommended for the recipient of an article to contractually
request its suppliers to notify whether or not substances from the
Priority Declarable Substances List1 are to be found in the article by
no later than end 2009. The first Priority Declarable Substance List
is expected to be issued by no later than end 2008.
3) Declarable substances list (DSL)
It is recommended for the recipient of an article to contractually
request its suppliers to organize proper tracking of the substance
within the article delivered in order to notify whether or not
substances from the Declarable Substances List2 are to be found in
the article being supplied by no later than end 2011. Between the
first publication of the Candidate List and end 2011, it is recom-
mended that each actor within the aerospace and defence value
chain implement IT systems enabling the reporting on the Declara-
ble Substance List. These IT systems should be configured so as
to integrate changes to the Declarable Substance List.
For more information on the DSL, please refer to ASD STAN TR
9536 or SAE ARP 9536. October 2008 End 2009 End 2011
REACH / Phased Declaration Process
Companies need to Companies need to be Companies need to be
4) Phased declaration process *Known to date declare against the able to declare able to declare
It is recommended during bilateral discussions between suppliers Likely to evolve candidate list as soon against the PDSL and against the DSL and
and customers to contractually refer to this document. in time. as it is published. the candidate list. the candidate list.
However, provided a bilateral contractual agreement, a customer
and its supplier can start reporting on the Declarable Substances
List before 2011 or any mutually agreed date.
1. The latest version available.
2. The latest version available.
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