REACH Part 2: Avoiding an equipment supply chain backlog


Construction equipment could go the way of the Sony PlayStation if equipment manufacturers don’t put the framework in place to deal with customs issues that could arise from enforcement from the European Union’s REACH (the Regulation on Registration, Evaluation, Authorisiation [sic] and Restriction of Chemicals). REACH regulates the use of chemicals in manufacturing, including construction equipment.

In the January 2014 Transportation Talk, I discussed what REACH was and how under the protocols for it, existing chemicals are identified as Substances of Very High Concern (SVHC). (See “The EU’s REACH regs have implications for U.S. equipment market” at There are substances always being added, and the list has been predicted to reach 1,000 by 2020.

That being said, just knowing about the regulations and being able to identify any substances on the list that are used in equipment – whether it’s an additive, paint, sealant or something else – isn’t enough. Back in 2002, the children anxiously awaiting a Sony PlayStation for Christmas were disappointed when 1.3 million of these gaming consoles and 800,000 accessory packs were held up at customs in the Netherlands because they were not in compliance with the cadmium laws. They were bundled with cables found to contain up to 20 times as much cadmium as is deemed safe. It’s not immediately toxic but can lead to kidney damage throughout time. However, it raises the point that this could very well happen to equipment and disrupt the current supply chain.

Michael Wurzman, president of RSJ Technical Consulting and a REACH expert, says he doesn’t expect any major effort to be lobbied against the industry, but “will be surprised” if there isn’t some enforcement coming up within the next few years and subsequent lawsuits. This means manufacturers need to not only be aware of these regulations but to have a standard data format “that allows us to address data that needs to be exchanged while protecting confidentiality but enables us with ways to trace through the supply chain,” Wurzman says.[email protected]

We need to put a structural framework in place to address the REACH issues and have customs paperwork ready. “This is the only way we can cost effectively allow for our companies to become compliant and also get a financial advantage.”

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It is essentially risk management for the supply chains and customers. You have to decide. Is it worth the risk not to prepare? The regulations aren’t new; they aren’t going away. More and more restrictions are a ticking time bomb, and you need to be prepared.

“There is no reason to believe they are [substances] toxic in Europe but not here,” Wurzman says. “We are essentially being forced to do what we should anyway.”

Are you ready?