REACH Requirements and Repaired/Refurbished Products

Question: Our company sells service replacement parts that can be incorporated into a system we produce, or sold as accessories. In some cases, they are repaired or refurbished units. Customers send us their old units, and we sell them refurbished products at a discount. In order to identify that the unit has been refurbished, we sometimes add a unique suffix to the end of the part number.

If the REACH Regulation applies to service replacement parts, we would include these items in our data export to the Assent platform. In the case of refurbished units, we make the assumption that they have the same components as a new part. If we were to replace a component due to it being non-compliant, we would replace it during refurbishing. We typically don’t set up a bill of materials (BOM) for these refurbished parts. In this case, can we refer to the new part’s BOM as the BOM of the refurbished parts?

Answer: REACH SVHC communication applies to the Article level, therefore, it does not distinguish between replacement or refurbished parts. If there is a clear and documented process that states a refurbished product has the same BOM as a new product, then one could simply have the suffix identifying it as a refurbished product put in the Assent Compliance Manager, but they would map to the same parts and suppliers just like a non-refurbished product with the same BOM.

In the case of the new component, if it was being imported into the European Economic Area (EEA) to replace part of an assembly, then the component would need to comply with REACH requirements at the point of import (i.e. have part data supporting REACH compliance). If the component was being replaced in a product outside of the EEA and then imported into the EEA, the entire product would need data related to all parts in the product as delivered. If this requires setting up a new BOM or some kind of flat part list to properly account, it would be important to export to the Assent platform.

Content current as of 2019-09-13.

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