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What is Bad Material Substitution?
July 29, 2016
Welcome to my first blog. I'm planning to use this space to highlight emerging product stewardship challenges. We'll explore one topic each time, and hopefully provide relevant insights for your company.
First topic: What is bad or "unsustainable" material substitution? Due to the September 2015 European Court of Justice ruling on REACH which places the threshold for Annex XIV restrictions at the single component level, instead of the imported article or product; companies must be evaluating the levels of substances found in tiny parts included by their suppliers' suppliers products. This creates a need for companies to have data systems in place to capture material content not only for all parts that they purchase, but also assure that their suppliers have collected appropriate data as well. Regardless of who manufactured what and where; a company importing into Europe will be held liable for the entire chemical content of their product.
How does this work in reality? For example, your company manufactures treadmills for import into Europe. Your design group specifies the materials for some of the main components such as the belt, the frame, and the deck; but you purchase the display and motor from other companies. Your Purchasing department has a policy of getting statements from your suppliers that their products are compliant to REACH, and your display supplier has stated compliance every year, as required. Now, they've found out that a substance on the list which will be banned as of next quarter is present in the plastic covering and tells you that they're changing plasticizers as soon as possible. What are your potential risks from this suppliers change?
1. They don't make the change before you are shipping non-compliant product into Europe.
2. They change to a alternate that isn't as good and your display cracks within the warranty period.
3. They change to a alternate also regulated with a deadline of next year, and are going to have to make another change within the next 6 months.
4. They change to a alternate that is banned in Japan, and your product is non-compliant there.
Substance and material substitutions are tricky. Environmental regulations vary across the globe with less restrictions found in regions that now do a lot of material and component manufacturing for many brands. In order to assure your products are compliant, a thoughtful approach to material substitutions is needed. The process works best when a company has good information from their entire supply chain and doesn't just rely on your direct suppliers and yearly statements. It is also becoming clear that companies will need to know their products chemical composition, even if they are just assembling parts bought from a distributor.