RPA was commissioned by the European Commission, Directorate General Environment, to contribute to a study led by Ökopol to provide scientific and technical support for collecting information on and reviewing available tools to track hazardous substances in articles.
The study aimed to provide an overview of the available tools that support the communication and management of hazardous substances in articles (SiA) in line with REACH Article 33. REACH Article 33 defines the communication requirements in the supply chain and to consumers for the presence of substances of very high concern (SVHC) in articles. The study identified and assessed instruments that facilitate communication of SiA within the supply chain (B2B – carried out by Ökopol) and those that facilitate communication of SiA to consumers (B2C – carried out by RPA). The study involved an initial description of the tools identified, for both B2B and B2C, and then consultation for those tools that were selected for further analysis. The B2B consultation involved interviews with tool owners, developers and users of the tools. The B2C consultation focused on practical testing of the selected tools by stakeholders, which included NGOs, including those representing consumer interests, public authorities and consumers.
The information tools that were investigated for B2B communication can be grouped under Complex IT Solutions, Generic Materials Databases, declarations of Compliance, (Manufacturing) Restricted substances lists ((M)RSL), Third Party Certification, Communication Standards, Product Markings and Other (such as ZDHC Chemical Gateway and SINlist). The information tools that were investigated for B2C tools were apps, requesting tools (internet), website, Wiki, databases, labels and certificates, test reports, ingredients lists and other (product bar codes, Pharos).
The study provides the European Commission with a level of understanding of the current market availability and use of SiA communication tools and what could be done to increase compliance with Article 33.