REACH and CLP in Electrical Engineering: How to Ensure Compliance of Chemical Raw Materials with Legislation in the Production of Electronic Components

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The manufacturing of electronic components, from printed circuit boards to insulating materials, relies on a wide range of chemical raw materials – from soldering adhesives and insulating resins to solder pastes. However, each of these substances must comply with the strict requirements of the REACH and CLP regulations, which govern their registration, evaluation, and classification. Non-compliance with these regulations can lead not only to legal penalties but also to risks for worker safety and end-users. How can you correctly assess whether your raw materials meet legislative standards, and what steps should be taken to ensure full compliance?

REACH and CLP: The Fundamental Framework for the Electronics Industry

The electronics industry works with a wide range of chemical raw materials, from insulating materials and solder pastes to additives for plastic components. For manufacturers of electronic components, it is crucial to ensure that all substances used comply with the requirements of the REACH (Registration, Evaluation, Authorisation and Restriction of Chemicals) and CLP (Classification, Labelling and Packaging) regulations. REACH focuses on the registration and evaluation of chemical substances, while CLP sets out the rules for their classification, labelling, and packaging. In practice, this means that every raw material must either be registered with the European Chemicals Agency (ECHA) or fall under exceptions, such as polymers or substances in low concentrations.

For electronics manufacturers, it is essential to be aware of which substances are on the Candidate List of Substances (SVHC – Substances of Very High Concern) or the Authorisation List. The use of these substances may be restricted or subject to authorisation. CLP also requires that all hazardous substances be properly labelled with warning symbols, standard hazard statements (H-phrases), and safety instructions (P-phrases). This applies not only to the raw materials themselves but also to finished products if they contain hazardous substances in concentrations exceeding the specified limits.

Safety Data Sheets (SDS) as a Key Compliance Tool

The Safety Data Sheet (SDS) is a fundamental document that provides comprehensive information on the chemical properties of a raw material, its risks, and measures for safe handling. In the electronics industry, an SDS must be available for every chemical substance or mixture used in the production process. The document must be prepared in accordance with current regulations and updated whenever there is a change in the composition or classification of the substance.

SDS contains 16 mandatory sections that cover everything from substance and supplier identification to hazard information, composition, first aid measures, fire-fighting measures, and instructions for handling and storage. For electronics manufacturers, Section 15 is particularly important, as it addresses regulatory information, including compliance with REACH and CLP. Suppliers of chemical raw materials are required to provide up-to-date SDS, but the responsibility for their correct use and adherence to instructions lies with the manufacturer. This also includes employee training and implementing internal procedures for working with hazardous substances.

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Classification and labelling of chemical raw materials according to CLP

The classification of chemicals under the CLP Regulation is crucial for ensuring safety in the production of electronic components. CLP introduces a harmonized classification system that categorizes substances based on their physical, health, and environmental hazards. For the electronics industry, categories such as flammability, toxicity, corrosivity, or environmental hazards are particularly relevant. Each category is associated with specific warning symbols (pictograms) and standardized hazard statements.

Manufacturers must ensure that all raw materials are correctly classified and labeled before being used in the production process. This also applies to mixtures that may contain multiple hazardous substances. For example, solder pastes often contain metal alloys and fluxes that may be classified as flammable or irritant. Labels must be visibly placed on packaging and in technical documentation. It is also important to monitor updates to classifications, as ECHA regularly reviews and updates the lists of hazardous substances.

Practical Steps to Ensure Compliance with REACH and CLP

For manufacturers of electronic components, it is key to implement a systematic approach to comply with REACH and CLP requirements. The first step is to create an internal list of all chemical raw materials used in production, including their suppliers and available safety data sheets. This list should be regularly updated and checked against the Candidate List of Substances (SVHC) and substances subject to authorization. If it is found that a raw material contains an SVHC in a concentration exceeding 0.1%, this information must be communicated to customers and, if necessary, replaced with a safer alternative.

Another important step is training employees who come into contact with chemical substances. The training should include information on the risks associated with individual raw materials, proper handling, storage, and disposal. It is also necessary to establish internal procedures for checking the labeling and packaging of raw materials in accordance with CLP. This includes regular inspection of warning symbols, H-phrases, and P-phrases on packaging and in documentation. Last but not least, it is important to collaborate with suppliers who provide raw materials in compliance with legislation and are able to respond quickly to any changes in regulations.

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Risk Assessment of Chemical Raw Materials in Electrical Engineering Applications

In the electrical engineering industry, risk assessment of chemical raw materials is a key step in ensuring safety and legislative compliance. The process begins with the identification of all substances used in production, including plastic additives, fluxes, cleaning agents, or coatings. Each raw material must be evaluated in terms of potential hazards to health and the environment, based on data from safety data sheets (SDS) and REACH registration documents. Special attention should be paid to substances with restricted use (e.g., phthalates, lead, or certain brominated flame retardants), which may be subject to specific restrictions.

Practical assessment involves analyzing exposure scenarios – for example, during soldering, bonding, or surface treatment of components. It is necessary to consider not only direct contact of workers with chemicals but also possible emissions of volatile substances into the air or contamination of wastewater. Manufacturers should collaborate with raw material suppliers to create detailed use scenarios covering the entire product lifecycle. These scenarios then serve as a basis for updating SDS and ensuring compliance with REACH requirements for information sharing in the supply chain.

Documentation and records for audits and regulatory authorities

Demonstrating compliance with REACH and CLP requires systematic documentation, which must be available for internal audits and potential inspections by regulatory authorities. The basis is a record of all chemical raw materials used in production, including their quantities, methods of use, and suppliers. For each substance, an up-to-date safety data sheet (SDS) and confirmation of REACH registration should be available if the substance is used in quantities exceeding 1 tonne per year. It is also important to monitor updates to SDS, which suppliers must provide in case of classification changes or new risk findings.

In addition to SDS, it is necessary to maintain records of employee training for those who come into contact with chemical substances, as well as records of measures to minimize risks (e.g., the use of protective equipment, workplace ventilation). For manufacturers of electronic components, it is also important to document procedures for handling waste containing hazardous substances. In the event of an inspection, all documents must be easily traceable and clearly structured to quickly demonstrate compliance with legislative requirements.

Integration of REACH and CLP Requirements into the Development Processes of New Products

The legislative requirements of REACH and CLP should be considered in the early stages of developing new electrotechnical products. When selecting materials, raw materials with the lowest possible risk to health and the environment should be preferred, ideally with available alternatives that are not restricted under REACH. Development teams should collaborate with procurement and legal departments to promptly identify potential supply issues or legislative restrictions. For example, the use of lead in soldered joints has long been restricted, making it necessary to seek replacements that meet both technical and legislative requirements.

Another important step is testing new materials for their chemical stability and compatibility with other components. Some substances may degrade or react with other materials during long-term use, potentially leading to the release of hazardous substances. Therefore, it is advisable to conduct accelerated aging tests on materials and analyze emissions using standard testing methods. The results of these tests then serve as a basis for updating safety documentation and ensuring compliance with CLP when labeling the final product.

Do You Need to Verify Compliance of Your Raw Materials?

GCG Group provides complete safety and technical documentation, including up-to-date SDS sheets, for every chemical raw material supplied. Our experts will advise you on selecting materials that meet REACH and CLP requirements for the electrical industry. Contact us – or browse our catalogue of over 1,300 products.