COG Quarterly Meeting Component Storage: Deceptive Safety

Tim Becker, REACHLaw, informiert über Obsoleszentrisiken aufgrund der Chemikalienverordnung REACH.
Tim Becker, REACHLaw, informiert über Obsoleszentrisiken aufgrund der Chemikalienverordnung REACH.

Yesterday there was a nasty awakening for many visitors of the Component Obsolescence Group (COG) quarterly meeting. The meeting was attended by around 120 representatives of companies who were interested in how to deal with obsolescence risks.

In most cases, manufacturers discontinue components due to life cycle or economic considerations. Tim Becker, Legal Advisor of the Finnish law firm ReachLaw, drew attention to the European chemicals regulation REACH, which can also lead to the discontinuation of components if they contain substances that are no longer permitted.

Companies that have to keep their products available in the long term protect themselves against early component terminations by stocking and storing critical parts. This storage can last for ten, twenty years or more. Within this time, substances contained in these components may become no longer be permitted. Then,placing the stored components on the market also becomes no longer permitted - and the whole investment in stockpiling and storage was a waste of resources.

Growing Requirements

The EU REACH Regulation aims to ensure that chemicals manufactured, imported, and used in the EU pose no risk to the environment or health and that the most dangerous substances are progressively replaced by safe alternatives. The focus is on substances of very high concern. The European Chemicals Agency ECHA is responsible for deciding which substances fall into this category.

If there is no alternative for a dangerous substance, then companies wishing to use such substances must apply for authorization. If the substance is then used in a product and its content exceeds 0.1% by mass, then the manufacturer must inform potential customers and consumers of this independently of a purchase.

Among other things, the REACH Regulation contains two lists: Annex 14 contains the list of substances subject to authorization whose use triggers the aforementioned information obligation. There are currently 43 substances on this list. Annex 17 contains the list of restrictions consisting of 68 substances whose use is either not permitted at all or only permitted under certain conditions. Furthermore, the chemical agency ECHA has a "candidate list" with currently 191 substances that are eligible for authorization or restriction. The lists are updated by ECHA every six months.

Companies that stock components now run the risk that the stored parts contain substances that  will be included in one of the two lists according to Annex 14 or 17 during the storage period. For this reason, it is advisable to observe ECHA's "candidate list" when designing assemblies and, if possible, to use components without these substances.

Information and Support

The Component Obsolescence Group (COG) raises awareness of obsolescence problems. To this end, quarterly meetings with informative lectures are held. The COG also defines processes, e.g., to automate the handling of obsolescence reports, and advocates the introduction of these processes among suppliers and customers of electronic components.