Question: Should we be concerned with substances used for cleaning products during the coating process of industrial equipment since it is not part of the final product?
Answer: For product compliance purposes, if the material is not present in the finished good, then it does not need to be declared. However, many companies prefer to collect information on processing chemicals in case chemicals, substances or materials become restricted from use or are discontinued. This foresight protects them against line of business disruptions and the possibility of price spikes. In addition, the use of cleaning products has been known to remain on the finished products. For example, dimethylformamide (DMF), a REACH SVHC, was found on many polyurethanes after it was used as a solvent during production and was not properly removed. The presence of DMF then triggered reporting requirements under REACH.
This information is accurate as of July 5, 2019.