REACH Implementation and Spare Parts
The European engineering industries represented by Orgalime welcome the debate initiated by the European Commission to address the challenges related to REACH implementation and spare parts, notably with regards to authorisation and restriction.
The issue for our industry is similar to that of the automotive and aerospace industries: our industry produces spare parts to ensure proper repair, re-use and upgrade of equipment, both in the B2C and the B2B area.
The availability of spare parts brings significant environmental benefits, as it guarantees longer product lifetimes and prevents waste generation earlier than necessary, which represent core elements of the EU’s resource efficiency policy objectives and the EU waste hierarchy.
Whilst the maintenance and repair of our products in both the B2B and B2C areas, may vary greatly depending on product type, users generally expect to be able to service, maintain and upgrade their equipment for a lengthy period of time, varying between 2-3 years for some consumer goods up to 15-20 years and more for capital goods. In the B2C field, the European engineering industries have to comply with legal warranty obligations established to protect consumer rights. In the B2B field, clauses in individual supply contracts impose legal warranty and maintenance obligations and spare parts availability too, while the sector faces long lifetimes and high reliability and safety requirements on equipment used in many critical technical applications, such as power plants, energy generation, transmission or distribution networks, chemical or any other industrial or manufacturing production site, hospitals, airports, harbours or airplanes.
It is therefore crucial that spare parts should be available in a timely and functional manner and at a reasonable cost for the maintenance, repair, refurbishment and remanufacturing so that such activities remain cost-effective, viable and overall sustainable.
Notwithstanding the 'Common Understanding of the REACH-RoHS', as currently under debate in CARACAL, we believe that concerning spare parts, there is an issue related not only to REACH authorisation but also to REACH restrictions (Annex XVII). The inclusion of a substance used in spare parts into Annexes XIV or XVII of REACH creates a number of challenges, which we detail in this paper [more in download]