TDK Electronics · TDK Europe

Frequently asked questions about REACH


1. What potential obligations are there for manufacturers of electronic components under the REACH regulations?

For manufacturers and importers of a substance:
If a substance is manufactured or imported or if a substance or several substances in formulations are imported in quantities of more than one metric ton per year, then a European manufacturer of electronic components has the same obligations as a manufacturer of a substance.

For manufacturers of articles:
There are basically two obligations. If more than one metric ton per year of a substance is intentionally released from the article, then that substance must be registered, if this has not already been done by a third party. If the article contains a substance of very high concern (SVHC) as published per REACH Candidates List above 0.1 percent per product weight, the manufacturer must provide the customer with information sufficient for the safe use of the article if available. As a minimum requirement, customers must be notified of the name of the substance (see also REACH Candidates List). From June 1st, 2011 on and under certain circumstances the ECHA must be notified with in 6 months after publication of the revised candidate list as well.

2. What time limits apply for notifying the ECHA and for informing customers?

Effective June 1, 2011, the ECHA must be notified within six months of the substance being identified. Notification is not necessary, however, if the content of the SVHC is less than 0,1% w/w or if the total amount of the SVHC in the affected articles is less than 1 ton per year and manufacturer (importer). Furthermore a notification must not be submitted, if the manufacturer or importer can rule out the possibility of exposure to humans or the environment under normal or foreseeable conditions of use. A notification does also not apply to substances that have already been registered for that use. REACH does not specify time limits for informing customers.

3. Are there cases when a substance must be registered if it is contained in an article?

The ECHA may decide that manufacturers or importers of articles must submit a registration dossier for a substance in these articles if the following two conditions are satisfied:

  • These articles contain the substance in quantities totaling more than 1 metric ton per year per manufacturer/importer.
  • The ECHA assumes that the substance will be released from the articles and the release of the substance from the articles poses a risk to human health or the environment.

4. Where can I find information on substances in TDK Electronics products?

Since 2002, TDK Electronics has published Material Data Sheets on its website that are based on IEC PAS 61906. The information on the composition of the substance relates to the component – as required by REACH. Because the composition of the substance is stated in full, these documents are sufficient, for example, to satisfy any potential customer notification requirement according to Article 33 of the REACH regulations.

5. What retention periods apply to documents where REACH is concerned?

Each manufacturer, importer, downstream user and distributor has to collect all the information required to meet his obligations under REACH and keep it available for a period of at least ten years after last production, import, delivery or use of the substance or formulation.

6. How has TDK Electronics prepared for its role(s) under REACH?

Back in 2006, the REACH Implementation Team (RIT) was set up under the leadership of the “Technology and Quality – Environmental Protection” department. The team is made up of representatives from the company’s legally autonomous locations in Europe. Regular meetings are held where the locations prepare for the tasks required under the REACH regulation.

7. Are non-European TDK Electronics locations affected by REACH?

Not in the legal sense.

8. The automotive industry wants to have a single point of contact in TDK Electronics. How does TDK Electronics meet this requirement?

The European locations have sole responsibility for implementation, so each location constitutes a single point of contact.

9. What help is available on REACH?

10. Who is a manufacturer, who is an importer? What is an article?

For definitions, please see Article 3 of the REACH regulations.

11. Do all substances that occur in components have to be registered?

Components are articles according to the REACH definition. Therefore, only substances

  • meant for intentional release and
  • processed in quantities of more than one metric ton per year

have to be registered (e.g. printer cartridges, markers, fire extinguishers, etc.). Because no substances are released from EPCOS products intentionally or under reasonably foreseeable conditions (including from aluminum electrolyte capacitors), registration is not required according to Article 7 (1) of the REACH regulations.

12. Is TDK Electronics REACH-compliant?

A management system certified to ISO 14001 is in place at TDK Electronics locations. This management system requires legal and other requirements to be reviewed and monitored. This includes REACH requirements.

13. Do TDK Electronics products contain substances of very high concern (SVHC)?

14. How does TDK Electronics communicate REACH-related issues?

TDK Electronics maintains contact with all affected parties in the supply chain. In October 2007, TDK Electronics started requesting information from suppliers and responding to enquiries from customers. Within the company itself, employees and department units affected are being prepared for REACH. TDK Electronics takes part in regular experience sharing in the RIT (see also question 6) and in technical committees of various associations. TDK Electronics also helped to develop the Helpdesk of the Federation of German Industry (BDI) and REACH workshops run by the German Electrical and Electronic Manufacturers’ Association (ZVEI). Through project work, TDK Electronics also contributed to the drafting of Guidance for Downstream Users and so is actively involved in the REACH process.