2023-03-06-ACEA-REACH汽车工业指南_88页_4mb

REACH Automotive Industry Guideline Summary

# REACH Automotive Industry Guideline

## Executive Summary
- REACH (Registration, Evaluation, Authorisation, and Restriction of Chemicals) impacts the automotive industry by requiring different obligations for various roles, including manufacturers, importers, and downstream users.
- Companies must comply with REACH to continue operating in the EEA market; failure may result in market exclusion.
- Key processes include substance registration (tons/tonnes), authorisation for very high concern (SVHC) substances, notification for candidate list substances, and restriction procedures for unacceptable risks.

---

## Key Compliance Steps
### 1. Raise Awareness
- Familiarize the supply chain with REACH requirements using tools like SDSComXML for electronic exchange.
- Establish an inventory of all substances/mixtures used in products to determine obligations.

### 2. Develop Substance Inventory
- Collect data on hazardous vs. non-hazardous substances, quantities (tons/tonnes), and uses.
- Identify role-specific obligations (e.g., importer, downstream user, article producer).

### 3. Declare Intent (3 Steps)
- Map supply chain roles for substance use.
- Request substitution information based on sustainable criteria (ACEA guidelines).
- Communicate needs to suppliers early to ensure uses are included in registration.

### 4. SVHC and Risk Management
- Identify low-discharge/replacement parts to avoid candidate list.
- Ensure substitution plans exist for restricted substances.
- Maintain records for up to 10 years.

### 5. Use Management & Obsolescence
- Manage end-of-life vehicle components.
- Prioritize substitution programs.

---

## Key Requirements
### 1. Registration:
- For substances intended to be released from articles (per ton) via Article 7.
- Tonnage bands (1-100 tpa, 100-1000+ tpa) determine timelines.
- Mixtures require registration only if hazardous; articles are exempt if produced >1 tonne per legal entity.

### 2. Authorisation:
- Apply for use of Annex XIV ("very high concern") substances.
- Submit applications when thresholds (sunset dates) are reached.
- Track review periods to extend if needed.

### 3. Notification & Communication:
- Deadline: Within 6 months of candidate list (CL) inclusion.
- Threshold: >0.1% concentration in articles (O5A principle).

### 4. Restriction:
- Address substances banned (e.g., Annex XVII for heavy metals).
- Risk-based surveys for consumer products with consumer exposure (art. 33).

---

## Conclusion
- Follow the AIG 5-step schedule for compliance.
- Work vertically across the supply chain to avoid duplication.
- Prioritize substitution for restricted substances per industry guidelines.