Frequently asked questions about REACH

For manufacturers and importers of materials:

If a substance is manufactured or imported, or if more than one metric ton of a substance or several substances in preparations are imported annually, then a European manufacturer of electronic components has the same obligations as the manufacturer of a substance.

For manufacturers of articles:

In principle, there are two obligations. If an article intentionally releases more than one metric ton of a substance annually, then the substance must be registered, unless this has already been performed by a third party. If an article includes a substance of very high concern and this consists of over 0.1% weight by weight (w/w), based on product weight, the manufacturer must provide the recipient of the article with information sufficient for safe use of the article if available and at least state the name of the relevant substance (see also www.tdk-electronics.tdk.com/reach_svhc). From June 1, 2011, in certain circumstances, the ECHA must be notified within 6 months, following the publication of the revised candidate list.

From June 1, 2011, the ECHA must be notified within 6 months of the the substance being identified. No notification is necessary if the substance in the affected articles is present in a quantity of less than 0.1% w/w or if the total quantity of the substance in the affected articles is less than one metric ton per year and per manufacturer (importer). Equally, no notification must be performed if the manufacturer or importer can exclude exposure to humans or the environment under normal or foreseeable conditions of use, including disposal, with this also being applicable for substances that have already been registered for the relevant use. REACH does not specify any deadlines for informing customers.

From June 1, 2011, the ECHA must be notified within 6 months of the the substance being identified. No notification is necessary if the substance in the affected articles is present in a quantity of less than 0.1% w/w or if the total quantity of the substance in the affected articles is less than one metric ton per year and per manufacturer (importer). Equally, no notification must be performed if the manufacturer or importer can exclude exposure to humans or the environment under normal or foreseeable conditions of use, including disposal, with this also being applicable for substances that have already been registered for the relevant use. REACH does not specify any deadlines for informing customers.

TDK Electronics has published material data sheets based on IEC PAS 61906 since 2002. As set down in REACH, the substance information is based on the product. As the composition of the substance is stated in full, these documents are sufficient for fulfilling a potential obligation to inform customers in accordance with Article 33 of the REACH Regulation, for example.

We also state substances of very high concern in the products that we currently offer separately in our REACH Candidate List, in accordance with the provisions on the REACH Candidate List. You can find our list at www.tdk-electronics.tdk.com/reach_svhc.

For queries on discontinued products or general questions, please contact your sales partner (TDK sales office or distributor). They can help you and may forward your query to our internal specialist departments.

Each manufacturer, importer, downstream user and distributor shall assemble and keep available all the information he requires to carry out his duties under REACH for a period of at least 10 years after he last manufactured, imported, supplied or used the substance or preparation.

No, not in a legal sense.

The European TDK Electronics locations are implementing this under their own responsibility, so each location provides a single point of contact.

For definitions, please refer to Article 3 of the REACH Regulation.

According to the REACH definition, components are articles. Therefore, only substances

• that are to be intentionally released
• of which over one metric ton will be processed per year (example: substances in printer cartridges, markers, fire extinguishers etc.)
  must be registered.

As no substances are released from EPCOS products (including aluminum electrolytic capacitors) either intentionally or under reasonably foreseeable conditions, registration under Article 7 (1) of the REACH Regulation is not required.

TDK Electronics has implemented a quality management system in accordance with IATF and an environmental management system in accordance with ISO 14001 in production locations. Legal and other requirements must be reviewed and monitored within the scope of these management systems. This includes the requirements as stated under REACH.

SCIP is a database by the European Chemicals Agency (ECHA) for information on substances of concern in articles or in complex objects (products) which has been established under the European Waste Framework Directive (WFD).

Companies supplying articles containing substances of very high concern (SVHCs) on the REACH Candidate List in a concentration above 0.1% weight by weight (w/w) on the EU market have since January 5, 2021 been obliged to register these articles by supplying information on them in the database.

Distributors are also affected by this insofar as articles (and other items) are sold to professional customers.

Packaging in itself is also considered an article.

An SCIP number refers to an actual article that is manufactured by a company and has been reported to the ECHA (containing one or several SVHC substances). The ECHA database confirms this report and allots the article an SCIP number.

This can be forwarded and used throughout the supply chain. However, there is no obligation to use or forward it.

We state our SCIP numbers for the relevant products that we currently have on offer in our REACH Candidate List, which you can find at www.tdk-electronics.tdk.com/reach_svhc.