A distributor asked for a substance statement on a Tuesday and wanted it by the end of the week. The answer took three weeks, because the declarations had never been collected from the suppliers and nobody could say which version of the candidate list the last statement had been written against. Five checks prevent that, and four of them are administrative.
REACH compliance for a charger: the five checks on the pack
Check the list version, the threshold and where it applies, the supplier declarations, the communication duty and the process for list updates.
The regulation places duties on the party placing the article on the market, and the duties that matter here are informational: knowing what is in the product, and passing that information along the supply chain in the form the rules require. The checks below are the practical version of those duties.
The work is documentation, which is precisely why it is deferred and why it becomes urgent at the least convenient moment.
Check 1: the substance list version the statement is based on
A statement is only meaningful against a version of the list.
The candidate list of substances of very high concern is updated periodically, and a declaration written last year was written against the list as it stood then. Record the version the statement was prepared against, so that the next update can be assessed rather than guessed. Where a customer asks for a statement without naming a version, the answer should name the version it uses.
Check 2: the threshold and where it applies in the product
The duty attaches to articles and to the concentration in them.
The relevant test is whether a substance is present above the concentration threshold in the article, and in a charger the article question is not always obvious: the product, its cable, its packaging and the accessories in the box may each be assessed separately. Confirm with the supplier which article a declaration covers, because a declaration that covers the material rather than the article leaves the concentration question unanswered.
Check 3: supplier declarations along the bill of materials
The declarations follow the same structure as the material evidence.
Each supplier declares for its own parts, and the file records the part, the supplier, the version of the list used and the date. Where a supplier cannot declare, the options are to test or to replace the part; where a supplier changes a formulation, the declaration has to be refreshed. Collecting these alongside the material declarations for the other chemical requirements avoids a second round of requests to the same suppliers.
Check 4: the communication duty to customers
Information has to travel down the chain, and that is a process rather than a document.
Where a substance above the threshold is present, the customer is entitled to the information needed to use the product safely, and the statement may be requested by distributors, retailers and marketplaces. The practical preparation is a standard response: the version of the list used, the parts assessed, the outcome and the date. Preparing that template once is what turns a three-week request into a two-day reply.
Check 5: what happens when a substance is added to the list
An update to the list is a trigger, not a notification.
When the list is revised, the parts assessed are reviewed against the new entries, starting with the materials most likely to be affected: coatings, plastics, solder and surface finishes. The outcome is either confirmation that nothing has changed or a targeted investigation of the parts that could contain the new substance. Keeping the evidence chain indexed by part and material is what makes that review a morning’s work rather than a project.
| Check | What to confirm | Evidence | Where it breaks |
|---|---|---|---|
| List version | The statement names the version it used | The statement itself | An undated or versionless statement |
| Threshold and article | Which article the declaration covers | Supplier declaration | Material covered, article unclear |
| Declarations | Every part has a current declaration | The indexed evidence chain | A supplier reformulated without notice |
| Communication | A standard response exists for customers | The prepared statement | Requests answered from scratch each time |
| List updates | A review process is triggered by a revision | Review record per update | Updates noticed by a customer |
How to run the checks before a shipment
Four steps, run in order, once per revision.
First, list the parts and materials in the product including the cable, the accessories and the packaging. Second, request the declarations against the current version of the list, giving the suppliers the threshold and the article definition rather than a general request. Third, file each response against its part in the evidence chain. Fourth, prepare the standard customer statement from that file so the next request is answered from a document rather than assembled from an inbox.
FAQ
Is a REACH statement the same as a RoHS declaration?
No. One addresses restricted substances in electrical equipment and the other addresses substances of very high concern with information duties attached. They are often requested together, and the underlying supplier conversations can be combined into a single request. One addresses restricted substances in electrical equipment and the other addresses substances of very high concern with information duties attached, although the supplier conversations can be combined.
Do we need laboratory testing for REACH?
Testing is used where a supplier cannot declare or where a material is unproven. For most charger programmes the evidence is supplier declarations, indexed by part and kept current against the version of the list in use. Test where a supplier cannot declare or where a material is unproven, and rely on declarations indexed by part and kept current for most programmes.
Who has to be told if a substance is present above the threshold?
The information travels down the supply chain, so distributors, retailers and other business customers receive the statement they need to use the product safely. Preparing a standard response is what keeps that duty routine. The information travels down the supply chain, so distributors, retailers and other business customers receive the statement they need, and preparing a standard response keeps the duty routine.
How often does the list change?
It is revised periodically rather than on a fixed schedule that a brand can plan around, which is why the process is triggered by the revision rather than by a calendar date. A review per update is the practical approach. The list is revised periodically rather than on a fixed schedule, so the process is triggered by the revision rather than by a date.
Next step
Send the bill of materials, the packaging and the customer requirement to Wecent Group through the contact page. The reply states which parts need declarations, how the evidence is indexed and what the standard customer statement would contain. Related reading: charger manufacturing services, our charger factory and the factory floor. External references: EU REACH Regulation, EU RoHS Directive, EU CE marking rules, EU energy-efficient products, IEC standards and Intertek testing services.
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