If you’re reading this article, chances are you work somewhere that requires you to maintain product compliance across a slew of regulations. If you are new to product compliance work, understanding the different compliance regulations and more importantly, how to keep up with them, is not an easy task. If your product or industry requires you to be compliant with several regulations, it can quickly become near impossible to manage this all on your own in light of constantly changing requirements. This blog will help break down a handful of common compliance regulations to help you better understand which ones apply to you and how Toxnot can be a solution!
California Proposition 65 is a law that was passed by Californian voters in 1986 and is overseen by California's Office of Environmental Health Hazard Assessment (OEHHA). The goal of this regulation was to protect drinking water sources from toxic chemicals that cause cancer and birth defects while also reducing and eliminating exposure to consumers through the implementation of warning labels for products that contain these harmful substances. The state of California and OEHHA maintains an annually updated list of toxic chemicals known to cause cancer, birth defects, and reproductive health. California Proposition 65 broadly serves to promote informed purchases and decision-making about exposure to chemicals of concern. California Proposition 65 compliance is required for all products sold in California, making it a requirement for a large number of manufacturers. Luckily, Toxnot maintains an updated list of California Proposition 65 substances and provides free compliance functionality allowing you to screen your entire library of products and materials against the regulation.
In 2012, the Securities and Exchange Commission adopted a new rule in the Dodd-Frank Wall Street Reform and Consumer Protection Act. This regulation now requires companies to publicly disclose their use of conflict minerals originating from the Democratic Republic of the Congo (DRC) or an adjoining country. These minerals include gold, tin, tantalum, and tungsten and can often be referred to as 3TG metals (extracted from cassiterite, columbite-tantalite, and wolframite minerals). These raw materials have been found to finance conflict in the DRC and this compliance regulation helps reduce the funding that perpetuates this regional violence. The EU also passed a similar regulation in 2017 to stop conflict minerals and metals from being exported to the EU, to stop smelters and refiners from using the conflict minerals, and to ensure miner safety. With the vastness of US and EU markets, it would be wise for manufacturers even beyond these regions to maintain conflict mineral compliance if using 3TG materials in the interest of sustainability and ethics across supply chains. Toxnot’s free compliance functionality also allows users to screen their products and materials against 3TG substances and create reports reflecting compliance.
EU REACH is a European directive that stands for Registration, Evaluation, Authorization and Restriction of Chemicals and is overseen by the European Commission. This regulation was established in 2007 and was created to replace previous legislation for toxic chemicals within the EU. The goal of EU REACH is to ensure a high level of protection for human health and the environment from harmful chemicals while also promoting alternative test methods and the free circulation of substances to further boost innovation. The EU maintains REACH chemical lists that are available to the public and substances range from chemicals used in industrial processes but also consumer products. REACH compliance requires manufacturers that sell in the EU to identify harmful substances in their products and manage risks associated with them as well as how they can be safely used. If risks cannot be managed, substances may be restricted entirely. REACH is admittedly one of the more complex compliance regulations in terms of submitting data and understanding the level of detail required, which may benefit from formal internal REACH training for compliance teams. Regardless, Toxnot allows the streamlining of REACH compliance by providing screening for substances and access to the different REACH substance lists (i.e. the Candidate List and the Authorisation List) in addition to a compliance report.
SCIP is a database for information on Substances of Concern In Products (SCIP) and is part of the Waste Framework Directive (WFD). WFD, like REACH, is a European Union (EU) piece of legislation that creates a structure in which manufactured products are managed and reported. REACH aims to improve protection and reduce the risk of human and environmental exposure posed by chemicals. WFD on the other hand addresses the adverse impact of waste generation and improves the efficient use of resources to promote the transition to a circular economy. ECHA created the SCIP database which requires companies that produce, import, or supply articles containing substances of very high concern (SVHCs) above 0.1% w/w to report that data into the database. The end goal is to help waste operators in sorting and recycling materials that contain SVHCs and support best use and disposal practices. The hope is that over time the SCIP database will help transition SVHCs out of supply chains and aid in the development of safer alternatives. Toxnot offers unique SCIP functionality, not only allowing you to screen your articles against priority lists, but to also send your SCIP notifications to the SCIP database directly through the Toxnot platform.
RoHS stands for Restriction of Hazardous Substances (also known as, Directive 2002/95/EC) and is a regulation that was enacted in July of 2006 by the European Union (https://www.rohsguide.com/). This standard specifically restricts hazardous substances found in electrical and electronic products, with 10 substances on this restricted list and associated allowance limits for these substances (i.e. <1000 ppm for all substances, with the exception of Cadmium at <100 ppm). RoHS exists to prevent hazardous substances from entering the environment and polluting landfills, while also protecting people from exposure during manufacturing and recycling. While only technically applicable to electrical and electronic products sold in the EU, this standard is observed by companies and industries around the world as supply chains become more connected to one another. Similar to the other compliance regulations, Toxnot allows you to screen against RoHS substances and create compliance reports for free.
Common across all of these compliance regulations are lengthy restricted substance lists (with thousands of chemicals in some cases) that are near impossible to manage on your own. Toxnot’s free compliance tools maintain updated lists for all of the above-mentioned regulations, allowing you to easily screen your supply chain for compliance. Additionally, Toxnot will notify you any time an updated compliance list impacts your product data, allowing you to sleep easy knowing that you’re compliant at all times. The supply chain surveying functionality also built into Toxnot provides an easy way to collect bill of material and compliance data from your suppliers to make all of the other steps a piece of cake.
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