Are cleaners used in the production process considered articles under regulations such as REACH and RoHS? For example, if sheet metal is cleaned with an industrial cleaner, do we have to report on the substances in that cleaner?
Industrial cleaners used in manufacturing processes are in scope of product compliance requirements if any part of the cleaner substances remain on the final product. If none remains, it is not considered to be part of the final product.
There are some manufacturers that may request information about process substances to understand the operational issues that could arise should those cleaners become restricted in some way.
However, if the cleaner itself is sold within the European Union (EU) (placed on the market), it would be in scope for the SVHCs, and potentially for any Authorisations (Article XIV) or Restrictions (Article XVII), depending on the substances contained. Furthermore:
- SVHC information would need to be shared with downstream recipients in the supply chain and consumers, if requested.
- If substances are on the authorisation list, authorisation for the uses of the substances in the cleaner would need to be in place after the sunset date.
- Substances listed on the Restricted list must meet requirements, whether they are “found over-a-specified-level” or “use-based” restrictions.
Reference (SVHC communication requirements): https://echa.europa.eu/
Reference (ECHA Understanding REACH): https://echa.europa.eu/
**Article contents valid as of 2019-03-18