REACH information in the Swedish HVAC product database, RSK-databasen

Directly after a substance is included in the Candidate List, suppliers of articles which contain such a substance in a concentration above 0.1% (weight by weight) have to provide enough information to allow the safe use of the article to the recipients of the article.

The legislation states that one must inform the recipient of the goods, but it is not described how to inform. The information along the supply chain shall enable all parties involved to take appropriate measures to ensure that goods containing substances on the candidate list are used safely. The information can be published online, if the supplier actively ensure that the customer is aware of the information.

Representatives of the Swedish wholesaler association Svenska rörgrossistföreningen VVS and the manufacturer organization VVS-Fabrikanterna have together defined how the information is to be handled in the distribution chain, between the manufacturer and the wholesaler, as below,

• Information recruitments according to REACH must be available at article number level.
• For articles covered by the obligation to provide information, it must be stated which substances are covered. Information shall be provided as one of the following documents; 1) safety data sheet for chemical products, 2) environmental product declaration or 3) REACH information sheet (not defined format, can be manufacturers own declaration). As a minimum the name of the substance in question has to be communicated.
• Date when control against the current candidate list was made.

The Swedish HVAC product database has been supplemented with fields for ”REACH dates” and documents ”REACH information sheets” as well as fields for whether the product is subject to the duty to provide information according to REACH. With this, the RSK database serves as an information hub for REACH information between manufacturers and wholesalers.

Note! The obligation to provide information according to REACH is only for substances that have been added as candidate substances in the candidate list and which occur in concentrations exceeding 0.1% by weight of the product. If this is not fulfilled, the field should be set to N (no) regarding duty to provide information according to REACH.

Information is sent to the responsible person at the manufacturer for RSK database in order to quickly update the information in the RSK database and thereby get a rational management of the information flow in the distribution chain, where each party can handle the information in an efficient manner.

Links

Candidate List of substances (https://echa.europa.eu/candidate-list-table)

Communication in the supply chain (https://echa.europa.eu/regulations/reach/candidate-list-substances-in-articles/communication-in-the-supply-chain)

Mall REACH informationsblad engelska – REACH template for RSK-databasen