The REACh European directive, a puzzle for articles manufacturers and distributors ?

At first glance, it seems that the answer is a plain yes : every actor of the manufacturing industry, every importer has to deal with hundreds, even thousands of suppliers and sub-contractors from all over the world on a daily basis.
The latter, understandably reluctant to communicate too much information to their customers’ purchasing services, are tempted , when required to remove some substances from their articles, to raise there prices.
This is no news to supply chain experts : the more actors are involved, the more difficult, time-consuming and therefore costly the data-collection process is (and , as we will see, the more efficient the resort to information technologies to achieve competitive gains proves to be).
If elegant solutions to seemingly insoluble problems do exist, let us first go through all there is to know about the REACh regulation as far as articles manufacturers and distributors are concerned,before talking solutions and alternatives.
REACH (Registration, Evaluation, Authorisation and restriction of CHemicals) is a genuinely revolutionary European regulation. In fact, it is so revolutionary that our American and Chinese friends are currently trying to come up with their own versions of the project.

REACH was at the core of the biggest lobbying battle of all times. No wonder, knowing what’s at stake. REACh’s raison d’être is to « ensure a high protection level of the human health and the environment, including promoting of alternative methods for the assessment of the dangers related to substances , as well as the free circulation of the substances on the internal market, and in the same time, boost competitivity and innovation » (source: article 1.1, Directive 2006/121/CE).
Basically, REACh will enable to scrap all the cancer-causing , environment-jeopardizing substances from the EU territory, in a mere decade !
This will result in significantly curbing the pression exerted on the Health services, and will consequently allow the member states governments to achieve substantial savings (amounting to several tens of billions euros).

Nevertheless, the investments necessary to carry out REACh are for a very large share made by companies (manufacturers and importers on the EU territory).
This is the result of the “reversal of the onus of proof” comprised in the REACh regulation: from now on, “the responsibility of proving that the substances can be manufactured, used and destroyed with no harm done to the human health and the environment” (source: Luxembourg REACH Helpdesk ). In other words, risk assessment is now shared by all the components of the industrial fabric.

This , along with dissuasive penalties -to say the least- (that can go as far as closing down an activity in compliance with the “No data, no Market” rule at the core of REACh) constitutes a strong incentive to collaboration between all the links of the supply chain.
If the implementation costs of the REACh regulation lay on companies, which requires some investments, these very companies are also the first to enjoy the direct benefits of the regulation. Those include :
A reduction of the “Health at work” related costs, with workers exposed a minima to substances of very high concern. This will lead to a rise of the labor’s longevity and will decrease the hardness.
Expected income : an enhanced competitivity of Europe and reindustrialization opportunities and relocalisation on the European soil of production units.
– because of the necessary effort to replace SVHC (Substances of Very High Concern), (see the notorious Annex XIV of the directive) research departments will have to serious focus their efforts on the eco-design topic.

This will impact the whole industrial chain of value (starting with the Production purchases spending category and subsequently the teams of buyers, who will seek new suppliers. ).

With the constant pressure exerted by the ongoing double trend of “responsible consuming” for consumers, and “responsible purchasing” for companies, the implementation of eco-conception via the suppression of cancer-causing, environment-threatening substances is a genuine bonanza for article manufacturers. The latter will indeed in the worst case scenario, strenghthen their positions with their existing customers, and in the best case scenario, reach new markets, craving cleaner products.

As stated in the well-known Article 33 of the REACh regulation, particularly aimed at articles manufacturers and importers, the most important element in a successful decision-making process is to have relevant data.
The question of the traceability of the chemical substances present within articles is at the core of REACh (remember the “No data, no Market” motto).

Easier said than done, when a product can involve up to hundreds of thousands of sub-contractors and suppliers.
That’s where the web comes : the web revolution consisted in annihilating the notion of geographical distance(“The World is Flat”) between people and information(Yahoo!, Google,…), between people and other people (Skype, Gmail, Hotmail, Facebook, MySpace,…), between people and companies (e-trade, institutional websites,…), between administrations and economic actors (dematerialized declarations), between companies and other companies (emails, webinars, EDI, XML,…).
The strength of the web is to facilitate relations, data collection, collaboration and information organization.
If doubts were once voiced concerning the fiability of web connexion and the safety of stored data, these doubts are now history in all industrialized countries thanks to the quality of the Internet infrastructures, and with the advent of cloud computing (tens of thousands of companies storing their most valuable data – their customers’ data- using the online CRM applications publisher Salesforce.com), even in highly sensitive industries (Banking or Defence industries).
Based on this observation, Verteego has developed, with its partner Messier-Dowty, world-leading manufacturer of undercarriages and a subsidiary of the SAFRAN Group, a unique web-based software solution named REACHGarden. REACHGarden was born to help manufacturers track down chemical substances within the supply chain (for articles manufacturers) or within articles suppliers (for distributors).
The benefits of this solution is to optimize for our customers the time spent by purchasers and REACh dedicated teams (QHSE, Supplier Performance or Purchasing Quality,…) by automating data collection campaigns, and to offer our customers a genuine competitiveness advantage compared to their competitors, still stuck with their spreadsheets sent by emails, or worse via call centers that annoy suppliers (when it’s not via plain old paper-based mail).
On top of this, it also guarantees a complete auditability of the collected data and does not require much time from suppliers.
So, back to our initial question. Is REACH that daunting a puzzle? Well, thanks to online platform REACHGarden.com which leverages all the possibilities of the Internet (collaboration, simplicity, traceability), REACh is obviously much easier to cope with.
Like all systematized procedures, this one requires some investment. The latter :
1) will be made profitable within 18 months at most;
2) are not significant when compared to the costs of a less systematized (one would even daresay less professional) procedure moins professionnelle);
3) are not significant when compared to the non-compliance costs.