Exporting to the European Union

We Can Help with Environmental Product Compliance Issues

For our customers who export products to the European Union (EU) or who sell to customers who export, compliance with EU environmental regulations is critical. We are frequently asked to provide a Certificate of Compliance to REACH (Registration, Evaluation, Authorization and Restriction of Chemicals), an EU regulation that was adopted in 2007 to reduce health risks from chemicals to both the environment and people. The European Chemicals Agency (ECHA) was established to administer the requirements of the regulation. Producers or EU importers of chemical substances must register with ECHA if they produce or import chemical substances in quantities of one ton or more per year.

Producers or suppliers of “articles” have lighter reporting duties than producers of “substances”. The regulation defines an article as “an object which during production is given a special shape, surface, or design which determines its function to a greater degree than its chemical composition”. All of Atkore products are considered articles due to the fact that the shape, surface, or design has a greater impact on the function of the product than the chemicals used to produce the product.

Usually, we are asked about REACH because one of our products is being used as a component in a product (another article) that is being exported to Europe (a Unistrut nut or bolt, for example, used in a wide variety of products). What do we have to do to satisfy inquiries about REACH compliance?

Under the REACH regulation, article manufacturers have an obligation to inform recipients of the presence of any Substance of Very High Concern (SVHC) that is listed on the ECHA Candidate List (substances such as hexavalent chromium and phthalates are on the SVHC list). Substances on this list may be used without consequence in articles if the total amount used does not exceed 0.1% by weight of the entire product. If an article contains a substance on the candidate list above a concentration of 0.1% by weight, additional obligations for the producer, importer or supplier may be triggered.

The only way article manufacturers can determine the presence of SVHCs in their products is to ask their suppliers if any of the components they are supplying contain any of the SVHCs above the allowable concentration limit. At Atkore, those inquiries are handled by the Industry Affairs team. When we are asked about REACH compliance, we have to analyze each product that we are supplying to the customer or manufacturer to determine whether or not there is anything in that product that is on the SVHC list above the threshold limit. Since the SVHC Candidate list currently consists of a 151 substances but is continually being updated, this can be a very time-consuming task.

The Industry Affairs Team at Atkore continually monitors the SVHC list and compares it to chemicals used in articles which Atkore produces. If you have any questions about REACH, contact Ray Horner at rhorner@atkore.com). As we analyze our products, we are building a database with REACH compliance results in order to provide accurate and timely information to our customers.