Many of Bremer’s customers demand compliance to regulations like CMRT, PFAS, Prop 65, REACH, and RoHS to avoid legal penalties, protect their brand reputation, gain market access, and meet consumer and investor expectations for product safety and ethical sourcing. These standards ensure products are safe for consumers and the environment, comply with specific market requirements (such as in California or the EU), and prevent disruptions in the supply chain by ensuring raw materials aren’t sourced from conflict zones or contain prohibited substances. Bremer regularly provides compliance documentation as required to meet these compliance requirements. Below are several of the regularly requested compliance requests we provide.
REACH
REACH is a regulation of the European Union, adopted to improve the protection of human health and the environment from the risks that can be posed by chemicals, while enhancing the competitiveness of the EU chemicals industry. It also promotes alternative methods for the hazard assessment of substances in order to reduce the number of tests on animals.
In principle, REACH applies to all chemical substances; not only those used in industrial processes but also in our day-to-day lives, for example in cleaning products, paints as well as in articles such as clothes, furniture and electrical appliances. Therefore, the regulation has an impact on most companies across the EU.
REACH places the burden of proof on companies. To comply with the regulation, companies must identify and manage the risks linked to the substances they manufacture and market in the EU. They have to demonstrate to ECHA how the substance can be safely used, and they must communicate the risk management measures to the users.
If the risks cannot be managed, authorities can restrict the use of substances in different ways. In the long run, the most hazardous substances should be substituted with less dangerous ones.
REACH stands for Registration, Evaluation, Authorisation and Restriction of Chemicals. It entered into force on 1 June 2007. (https://echa.europa.eu/regulations/reach/understanding-reach)
ROHS
The rise in the production and use of electrical and electronic products, such as mobile phones, computers and kitchen appliances, has resulted in an increasing volume of electrical and electronic waste. During the use, collection, treatment and disposal of such waste, products may release harmful (hazardous) substances such as lead, mercury and cadmium, which can cause major environmental and health problems.
To address such challenges, EU laws restrict the use of certain hazardous substances in electrical and electronic equipment through the RoHS Directive. In parallel, the WEEE Directive promotes the collection and recycling of such equipment.
The RoHS Directive currently restricts the use of ten substances: lead, cadmium, mercury, hexavalent chromium, polybrominated biphenyls (PBB) and polybrominated diphenyl ethers (PBDE), bis(2-ethylhexyl) phthalate (DEHP), butyl benzyl phthalate (BBP), dibutyl phthalate (DBP) and diisobutyl phthalate (DIBP).
All products with an electrical and electronic component, unless specifically excluded, have to comply with these restrictions.
In 2017, the Commission adopted a legislative proposal adjusting the scope of the RoHS Directive. (https://environment.ec.europa.eu/topics/waste-and-recycling/rohs-directive_en)
CMRT
Conflict minerals are minerals mined in regions where armed conflict and human rights abuses are rampant, often used to finance these groups. The term typically refers to four minerals—tin, tantalum, tungsten, and gold (3TG)—which are essential components in many electronic devices and jewelry. These minerals can fuel violence, as armed groups often control mining sites and use the profits to fund their activities. https://www.responsiblemineralsinitiative.org/about/faq/general-questions/what-are-conflict-minerals/
PFAS
FAS (per- and polyfluoroalkyl substances) are a large group of human-made chemicals that are resistant to heat, water, stains, and grease. Because they are durable, they are used in hundreds of products, including nonstick cookware, water-repellent clothing, stain-resistant carpets, and firefighting foams. They are often called “forever chemicals” because they do not break down easily and can build up in the environment and in people’s bodies. https://www.epa.gov/pfas/pfas-explained
Prop 65
California’s Proposition 65, or the Safe Drinking Water and Toxic Enforcement Act of 1986, is a California law that requires businesses to provide “clear and reasonable warnings” about potential exposure to chemicals known to cause cancer or reproductive harm. The law also prohibits the discharge of these chemicals into sources of drinking water. This is why you often see a warning label on products sold in California that states a product contains chemicals known to the state to cause cancer or reproductive harm. https://oehha.ca.gov/proposition-65/about-proposition-65
TSCA
TSCA, or the Toxic Substances Control Act, is a U.S. law administered by the Environmental Protection Agency (EPA) that provides the EPA with authority to regulate chemical substances and mixtures manufactured, imported, or processed in the United States. The act requires manufacturers to report and test chemicals, and allows the EPA to restrict or ban those that pose an unreasonable risk to human health or the environment. https://www.epa.gov/laws-regulations/summary-toxic-substances-control-act